1) Introduction
We are Mogford Limited, trading as The Oxford Collection, which includes the Old Bank Hotel, Old Parsonage Hotel, Quod Restaurant & Bar, Parsonage Grill, and Gees Restaurant & Bar. In this privacy notice, we refer to ourselves as “The Oxford Collection,” “we,” “us,” or “our.”
The Oxford Collection is committed to respecting the privacy of all individuals who visit our properties or use our websites.
This Privacy Policy applies to personal information that is either provided to us directly when you stay or inquire about staying with us, or that we collect when you visit any of The Oxford Collection’s websites or when we receive it through our communications with you.
In the subsequent sections of this Privacy Policy, we outline the types of personal information we gather, the purposes for which we use this information, the parties with whom we may share it, and the choices and rights you have concerning the use of your personal data. We also detail the security measures we have in place to safeguard your personal information and provide information on how to contact us regarding our privacy practices and how to exercise your rights.
We might change this page in the future, so please check it from time to time to make sure you’re okay with any changes. By continuing to use our websites you are agreeing to be bound by this privacy notice.
If you have questions about your privacy or how we protect your rights as a customer, subscriber, or website user, please contact our Data Protection Officer. You can email them at ku.oc.drofgom@opd, write to Mogford Ltd, 10a Woodstock Road, Oxford OX2 6HT, or call 01865 511115.
If you’re unhappy about how we collect and use your information, you can complain to the Information Commissioner’s Office (ICO), which is the UK authority for data protection issues (www.ico.org.uk). We’d appreciate it if you could contact us first with your complaint so we can try to resolve it for you.
It’s important that the information we have about you is accurate and up to date. If your personal information changes, please let us know by emailing us at ku.oc.drofgom@opd.
Sensitive Data
The only Sensitive Data that we may collect and store is information about health (allergies to certain food types or materials/cleaning products, and disabilities where access to certain areas of our businesses is effected), and potentially religious beliefs (for example if bedrooms facing in certain directions are required, or dietary requirements like Halal food). We do not store sensitive data such as race or ethnicity, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, or information about criminal convictions and offences.
2) How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at ku.oc.drofgom@opd.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at ku.oc.drofgom@opd if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity = To register you as a new customer.
Type of data = (a) Identity, (b) Contact.
Lawful basis for processing = Performance of a contract with you.
Purpose/Activity = To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us.
Type of data = (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications.
Lawful basis for processing = (a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us.
Purpose/Activity = To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy, (b) Asking you to leave a review or take a survey.
Type of data = (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications.
Lawful basis for processing = (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Purpose/Activity = To enable you to partake in a prize draw, competition or complete a survey.
Type of data = (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications.
Lawful basis for processing = (a) Performance of a contract with you, (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
Purpose/Activity = To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data = (a) Identity, (b) Contact, (c) Technical.
Lawful basis for processing = (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation.
Purpose/Activity = To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising.
Type of data = (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical.
Lawful basis for processing = Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
Purpose/Activity = To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data = (a) Technical, (b) Usage.
Lawful basis for processing = Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.
Purpose/Activity = To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data = (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile.
Lawful basis for processing = Necessary for our legitimate interests to develop our products/services and grow our business.
Marketing communications
You will receive marketing communications from us if you have:
- (i) requested information from us or purchased goods or services from us; or
- (ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- (iii) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at ku.oc.drofgom@opd.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
3) Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Opera by Oracle who gather and store your information for room reservations for both of our hotels and hold your information connected to private dining, conferences or meeting/business events.
- P3 Hotels who gather and store your information for room reservations for both of our hotels.
- OpenTable who manage table reservations for all three of our restaurants, and store your information in relation to table bookings.
- Campaign Monitor who store your details for our mailing lists and will only use your data to send you emails when we action this request, after you have opted in as a subscriber.
- Tell The Chef (Creventa) who gather your information for pre-ordering purposes.
- Signable to process contracts.
- SK Chase who process and supply our gift vouchers and store your information in connection to these.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
4) International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at ku.oc.drofgom@opd if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5) Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6) Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we 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 process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information.
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.
7) Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at www.ico.org.uk. If you wish to exercise any of the rights set out above, please email us at ku.oc.drofgom@opd.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8) Information Automatically Logged
We use your IP address to help diagnose problems with our server and to administer our websites. Your IP address is also used to gather broad demographic information. We also collect information with regard to referrers and exit points, again, to help diagnose problems with our server and to administer our websites.
9) Cookies
A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself. A cookie cannot read data from your hard disk or read cookie files created by other sites. Cookies, however, enhance our web site performance in a number of ways, including providing a secure way for us to verify your identity during your visit to our websites and personalising your experience on our websites, making it more convenient for you.
Our websites use Google Analytics Tracking, visitor software that uses cookies to track information about how visitors come to the websites, which pages they visit, and other actions that visitors make whilst on the sites. This data is then used in order to improve the user experience of the websites. All user data collected in this manner is anonymous.
Should you wish to do so, you can refuse cookies by disabling them in your web browser’s settings, and you do not need to have cookies turned on to successfully use our services. Most browsers are defaulted to accept and maintain cookies and you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or not. Please consult the support documentation for your web browser, which can be found online, for more information.
10) External Links
Our websites contain links to other websites outside of our company. We are not responsible for the privacy practices or the content of such websites so encourage you to read the Privacy Notices on the other websites you visit even if you access them using links from our websites.
In addition, if you clicked a link to one of our websites from a third party site, we cannot be responsible for the practices of the operators of that third party site and recommend that you check their Privacy Notice separately.
