PRIVACY POLICY AND NOTICE ON THE PROCESSING OF PERSONAL DATA
Last Updated: April 2024
Cadogan Hotel Partners Limited trading as The Cadogan Lounge by Benoit Blin (“The Cadogan Lounge”, “we”, “us” or “our”), respect the privacy of every individual who visits our Restaurant. This Privacy Policy applies to personal data that:
This Privacy Policy applies to personal data that:
- is provided to us when you stay or travel with us (or make enquiries to stay or travel with us) either by you or by a third party through whom you have made an enquiry or booking; and
- we collect from you when you visit any of Belmond’s websites or which we obtain from any communications with you.
The following sections of this Privacy Policy describe the types of personal data we collect, how and for what purposes we use that personal data, with whom we share it, and the choices and rights available to you regarding our use of your personal data. We also describe the measures we take to protect the security of the personal data we hold and how to contact us about our privacy practices, and to exercise your rights.
Click on one of the links below to jump to the listed section:
1. Data Controller
2. Personal data we collect
3. Use of personal data
4. Sharing personal data
5. Your rights
6. Data transfers
7. How we protect your personal data
8. How long we keep personal data for
9. Links to other websites
10. Updates to our Privacy Policy
11. California Consumer Privacy (California Residents only)
12. How to contact us
1. Data Controller
Cadogan Hotel Partners Limited trading as The Cadogan Lounge by Benoit Blin (UK company number 08775499) is the data controller with respect to your personal data.
For the avoidance of doubt, The Cadogan Lounge restaurant is an independent controller from Belmond Group or from The Cadogan Hotel.
2. Personal data we collect
2.1 Personal data you provide on a voluntary basis
We will collect, store and process information about you if you voluntarily provide us with such information in connection with the following:
- filling in a form on any of our websites;
- filling in a physical registration card;
- opting in to receive marketing information with us;
- creating an on-line account with us and managing your preferences;
- contacting by telephone conversations, face-to-face interactions such as at the reservation desk or during the check-in/check-out process, interactions with our concierge and customer service desks, during the use of our in-house services such as restaurants, bars, and housekeeping;
- sending us a letter, e-mail or social media message;
- subscribing to receive a service from us (e.g. a newsletter, blog or by following us on social media);
- requesting promotional information from us (e.g. information about any of our goods or services including The Cadogan Lounge gift cards);
- participating in a survey, competition or prize draw; or
- contributing content to us (e.g. for display on a Belmond blog).
The types of information we may obtain include:
- name, address, date of birth, email address, telephone number
- passport and visa data, payment data, travel history and details of joint travellers;
- dates of your stay or travel with us and associated charges;
- purchase or delivery of products or services;
- reviews and opinions about our brands, products and services;
- information we receive about you from any third parties through whom you have booked your arrangements; and
- information we receive about you from other members of The Cadogan Hotel (which may include information relating to a specific booking, travel dates, details of payments made to us, special requests and other information relating to your personal preferences (e.g. food and beverage preferences and interests).
‘Special category’ personal data
We do not collect data which is, by its nature, particularly sensitive (e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership) unless it is volunteered by you.
We may use certain sensitive (or “special category”) personal data where you have given your explicit consent to us doing so, to better serve and meet your needs. Such sensitive data is only shared with other members of the Belmond Group or our third party service providers acting as data processors (e.g. excursion providers, restaurants, transport providers) for the purpose of providing the services you request and will not be shared or used by us for any other purposes.
Examples of sensitive personal data we may collect and process include:
- food allergies;
- dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
- mobility requirements;
- disabilities; and
- medical conditions.
2.2 Personal data we collect automatically
When you visit The Cadogan Lounge website, we may also collect certain data through the use of “cookies” and other automated means. Cookies are small pieces of data that are stored by your browser on your computer's hard drive. We use cookies to gather data about the visitors to our websites, to enable us to improve our websites and deliver a better and more personalised service.
Data we collect through such means may comprise the following:
- date and time;
- originating IP address;
- domain name;
- type of browser and operating system used (if provided by the browser);
- URL of the referring page (if provided by the browser);
- object requested;
- completion status of the request;
- geographic location; or
- language preferences.
To learn more about cookies, how they are used and how to exercise your choice with respect to their collection of information on this site, please click here.
Please note that the Belmond website (www.belmond.com) uses YouTube API Services, in relation to the videos we showcase. By using the Belmond website, you agree to be bound by the YouTube Terms of Service applicable to the YouTube API Services. A copy of those YouTube Terms of Service is available at https://www.youtube.com/t/terms
Back to top3. Use of personal data
We will only use your personal data for the purposes and legal bases set out below:
| Purpose | Legal Basis |
|---|---|
| We will use your data on the date and time of interactions, originating IP addresses, geographic locations, types of browser and operating systems used, URLs of referring pages and language preferences to make improvements to our website and social media pages and ensure that content is presented effectively. | Legitimate interest in improving digital platforms. |
| We will use your name and contact details to send you direct marketing and produce other content in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. | Your consent. |
| We will use your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences, information we receive about you from any third parties to facilitate bookings, payment, and other administrative processes related to your stay and dining experience. | Legitimate interest in efficient service provision. It is necessary for us to process your personal data in order to perform our contract with you. |
| We will use your name, date and time of visit, and purchasing patterns to assess and understand general trends and patterns relating to our business. | Legitimate interest in business analysis and development. |
| We will use your name, address, date of birth, passport and visa data, travel history and details of joint travellers; dates of your stay or travel with us, information we receive about you from any third parties or from other members of the Belmond Group to ensure the safety and security of yourself and our guests and visitors. | Legitimate interests in ensuring the safety and security of our premises and occupants. |
| We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences to manage general record keeping. | Legitimate interest in maintaining accurate records. |
| We will collect, use and store your date and time of visit, originating IP address, domain name, type of browser and operating system used, URL of the referring page, object requested, completion status of the request, geographic location, and language preferences to compile statistics to understand how our website, services, and restaurant are used, and to improve operations. | Your consent for the use of cookies. Legitimate interest in operational improvement and analytics. |
| We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences, reviews and opinions about our restaurant, and information we receive about you from any third parties to provide personalized services and improve our products and services based on user preferences. | We have a legitimate interest in promoting our services to our customers. |
| We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by applicable law. | Necessary for compliance with a legal obligation. |
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
We may also use your personal data to enhance your Cadogan Lounge experience. We may use the information you provide us, including your preferences details, to offer you a personalised and unique experience. We sometimes analyse or anticipate aspects related to your preferences, interests, and behaviour to tailor our services (including our marketing communications) and better suit your needs. We do this based on our legitimate interests. We understand and respect that not everyone may want their data to be used this way. Therefore, you have the right to opt-out of this personalisation at any time.
You can opt-out of profiling by:
- Clicking unsubscribe in marketing communications;
- Emailing unsubscribe.CAD@belmond.com stating that you want to opt out of profiling;
- Contacting us using the contact details provided in Section 12 of this Privacy Policy.
Please note, once we receive your opt-out request we will action it as soon as possible but please allow up to 10 business days for your request to take effect.
We may process your personal data by both automated and manual means. We may use your personal data in other ways for which we provide specific notice at the time of collection.
Back to top4. Sharing personal data
We do not sell, otherwise disclose, or share data we collect and hold about you, except as described in this Privacy Policy.
We may share your personal data with third parties as described below:
- members of the LVMH Group, or affiliated companies, which may use this data to offer products and services to you consistent with the purposes identified in this Privacy Policy;
- third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with personal data necessary to perform the services on our behalf but are not authorised by us to use such data for any other purposes (e.g. providers of services in respect of web hosting, payment processing, information technology systems, customer relationship management, booking and reservations management, marketing, auditing, administration);
- reservations management platforms used by you or The Lalee to make reservations at The Lalee, such as SevenRooms;
- to our advisors and insurers in the event of a claim, dispute or where otherwise necessary;
- if we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or other government official; and
- we reserve the right to transfer personal data about you in the event that we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your data with any inquiries concerning the processing of that data.
- Right to Access - to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
- Right to Rectification - to request that we rectify or update any personal data that is inaccurate, incomplete or outdated;
- Right to Erasure - to request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
- Right to Restriction of Processing - to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
- Right to Withdraw Consent - where you have given us consent to process your personal data, to withdraw your consent; and
- Right to Data Portability - to request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.
- the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
- we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority.
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5. Your rights
We will only send you marketing communications if you “opted in” to receiving such communications. You have the right to “opt out” of receiving marketing communications, whether by email or otherwise, at any time. You can do this by (i) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, (ii) emailing unsubscribe.CAD@belmond.com to indicate you no longer wish to receive marketing communications, or (iii) writing to us at the relevant address set out in How to contact us below.
Pursuant to California's "Shine the Light Act", California residents are permitted to request information about the manner in which we share certain categories of data with third parties for their marketing use.
If you are a “data subject” under applicable data protection law in the EU or United Kingdom, you will have the following rights in relation to personal data that we hold about you:
To exercise your rights as set out above or to make a complaint or submit an inquiry about our privacy practices, please contact the Belmond Group Data Protection Officer by (i) email at dpo@belmond.com, or (ii) writing to us at the relevant address set out in How to contact us below.
To help protect your privacy and maintain security, we may take steps to verify your identity before we can action your request.
Back to top6. Data transfers
We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States, Canada or other destinations outside the European Economic Area (“EEA”) and the United Kingdom. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA and outside the United Kingdom.
If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:
You may request more information about the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in How to contact us below.
Back to top7. How we protect your personal data
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Service providers and contractors who might have access to your data in order to provide services on our behalf will be contractually obliged to keep such data in confidence, provide adequate data security measures, and may not use that data for any other purpose.
For your own protection, we encourage you not to include sensitive personal data, credit card or similar personal data in any e-mails you send us or our staff.
Back to top8. How long we keep personal data for
Belmond only retains your personal data for as long as needed to fulfil the purposes for which it is collected, unless we are required or permitted by law to keep the personal data for longer.
For a more detailed breakdown, view Belmond's data retention policy
Back to top9. Links to other websites
Our websites may provide links to other websites for your convenience and information. These websites operate independently from us. Linked websites may have their own privacy policies, which we strongly suggest you review. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.
Back to top10. Updates to our Privacy Policy
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our processing of your personal data and privacy practices. We will post a prominent notice on each of Belmond’s websites to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.
Back to top11. California Consumer Privacy (California Residents only)
Specific laws apply to the personal information of Californian residents. Please click here for further information.
Back to top12. How to contact us
If you have any questions or comments about this Privacy Policy, the use of cookies, if you would like us to update personal data we have about you or your preferences, or to exercise Your rights (as detailed above), please email our Belmond Group Data Protection Officer at dpo@belmond.com or write to us at:
Belmond Group Data Protection Officer
The Cadogan Lounge by Benoit Blin,
75 Sloane Street, London, SW1X 9SG, UK
In the unlikely event that you wish to lodge a complaint about our collection, transfer or processing of your personal data, you can lodge a complaint with the UK Information Commissioner’s Office which is the Supervisory Authority of Belmond Management Limited or the Supervisory Authority in your country of residence.
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