Privacy Policy | Celesta Venues

Celesta Venues, part of Imperial College London, is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you when you; enquire about or book our summer accommodation bedrooms, event spaces or any other product or service we provide; attend networking event or trade show and provide your contact details; or engage with us in any way.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. We may update this notice at any time.

Celesta Venues, part of Imperial College London, is committed to protecting the privacy and security of your personal information.

Information we hold about you

We may collect and process the following data about you when you enquire or book any of our accommodation bedrooms, event spaces or services, attend events, sign up for our communications, or request other services.

Information you give to us

We may collect, store and use the following categories of personal information about you:

Personal contact details: First name, last name, title, billing address, postal address, telephone numbers, personal email addresses, location of employment of workplace and photographs where you have attended an event on campus.
Transaction data: Records of payments made to us in relation to your booking.
Booking details: Information relating to your accommodation booking including the length of stay, arrival and departure dates; information relating to your event booking including dates, catering requirements, delegate information, dietary requirements; records of communications and interactions we have had with you.
Technical website data: includes your Internet Protocol (IP) address, browser type and version, location, operating system and platform.
Communication details: Your email address and communication preferences.

We may also collect, store and use the following ‘special categories’ of sensitive personal information:

Dietary requirements, including allergies.
Health and medical information where special assistance is required during your booking.

Information we collect about you

In the case of events and group accommodation bookings, where a third-party is responsible for individuals on campus, we may collect the following information about each individual person associated with that booking, this may include under 18s. Data includes:

Full name
Email address
Dietary requirements (special category)
Heath and medical information where special assistance is required during your booking.

How is your personal information collected?

We collect personal information about you in the following ways:

Information you give to us. You may give us information about you by making a booking online, completing and submitting a contact form on our website or by corresponding with us by phone, email or otherwise.
Information from third parties.
- When you make an accommodation booking through a travel agent (including online booking engines), group organiser or agent, we will receive information about you.
- When you submit an enquiry or book an event through an online listings website or event planning agency, your details will be shared with us.
- Through professional social media network, LinkedIn, unless you opt-out.
- From external data sources where you have opted in.

How we will use information about you

Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you or in order to take steps at your request prior to the entry into a contract.
Where we need to comply with a legal obligation.
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. Usually this will include:
- For internal record keeping
- For monitoring and evaluation purposes
- To take photographs, audio and video footage at events held on campus for use in digital and printed promotional materials, communications, publications and social media sites.
Where you have consented to the processing.
Where it is necessary in order to protect your vital interests or someone else’s vital interests.

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below.

Enable us to perform our contract with you:

To provide you with the information and services that you request from us.
To contact you in relation to your enquiry and/or booking, including for the purposes of feedback.
To notify you about changes to our service.
To administer and fulfil requirements as agreed in the contract and any related terms and conditions.

To comply with legal obligations:

To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your contract.
Complying with health and safety obligations.
Business management and planning, including accounting and auditing.
To prevent fraud.

For legitimate interest purposes, provided your fundamental rights do not override these:

To ensure the information we hold about you is up to date and accurate.
To inform you of any changes to our website, services or goods and products.
To provide you with relevant news and special offers by email, text message, phone or post.
To improve our interaction with you through tracking methods, for example which would allow us to see when you have interacted with one of our emails or adverts.

As part of yours or someone else’s vital interest

In the case of a life or death situation such as a medical emergency and consent is not possible to be obtained.

With your consent:

To provide you with information about our accommodation and event services that we feel will be relevant to you. We will only send you electronic marketing messages in the following situations:

You have submitted an enquiry or made a booking, either directly or via an online provider, and asked us to do something such as answer a question, provided information or do some other action on your behalf;
You have signed up to our online mailing list.

If you do not want us to use your data in this way you can opt out of these at the point that we collect your data or use the unsubscribe link in our email communications at any time after our initial contact.

Please note that in order to ensure that the content of our electronic communications is relevant to you, we may send some of these based on specific information you have provided.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or respond to your enquiry.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

In some cases we may need to process sensitive personal information that you have provided or we have collected about you. We will only collect sensitive personal information outlined earlier in this Privacy Notice and for the reasons below:

In limited circumstances, with your explicit written consent.
Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent.
Where the processing relates to personal data which have been manifestly made public by you.
Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
Where the processing is necessary for reasons of substantial public interest, and occurs on the basis of a law that is, inter alia, proportionate to the aim pursued and protects your rights as a data subject.
Where the processing is required for the purpose of medical treatment undertaken by health professionals, including assessing the working capacity of employees and the management of health or social care systems and services.

Our obligations

We will use your particularly sensitive personal information in the following ways:

We will use information about your physical or mental health, or disability status, to ensure your health and safety during your accommodation or event booking, and to provide appropriate adjustments.

Do we need your consent?

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Data sharing

Who we share your information with?

We will share your data with third parties and other entities in the College group where we have a legal basis to do so, where it is necessary to administer the relationship with your, or where we have another legitimate interest in doing so. The following third-party service providers process personal information:

HotelRez: Our online booking engine, when you book accommodation directly via the Imperial website.
Speedy Booker: Our online booking engine, when you book accommodation directly via the Imperial website.
Kinetics: Our booking management system, your data is added to allow us to process your booking and fulfil our contract with you.
Noonan: Our external cleaning contractor, data and special requests will be shared when accessing reservations.
External event suppliers where you have specifically requested we do so or it is necessary to facilitate your booking.
Qualtrics: Our online form provider, your data is shared when you submit an enquiry or complete a feedback form.
Mailchimp (The Rocket Science Group LLC): Our third-party email marketing provider.
Studio Noel: External branding agency, where we have permission to share data for the purposes of market research.
The Digital Maze: Website development agency, where we have permission to share data for the purposes of market research.
LinkedIn: Professional social networking site, for the purposes of providing targeted advertising, where you have not opted out of receiving marketing from us.

Some, non-identifiable, personal data may also be shared with our contractors and service providers who process data on behalf of Imperial Summer Accommodation to perform certain business-related functions. These include:

External marketing agency, Accord – Access to website analytics including location, browser and language, via the use of website cookies
External branding agency, Studio Noel
External Search Engine Optimisation agency, Hatch Internet Marketing
External website agency, The Digital Maze

Data will only be shared using secure data transfer methods and stored by us and our partners on secure systems. We and our partners will not use your personal data in any way that would affect you individually.

Transferring information outside the UK/EU

We may transfer the personal information we collect about you to the following country outside the UK/EU; USA in order to perform our contract with you.

There is not an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your data is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:

Implementation of additional Contractual provisions
Implementation of Standard Contract Clauses
Creation of Transfer Risks Assessments which reviews the country where data will be sent.

Data security

We have put in place measures to protect the security of your information.

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 have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information 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. Details of retention periods are as follows:

Contact details for marketing purposes will be kept indefinitely unless you withdraw your consent.
Contracts will be kept for at least 10 years from the date of expiry of such contract.

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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the College’s Data Protection Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the College’s Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at:

Imperial College London
Data Protection Officer
Exhibition Road
Faculty Building Level 4
London SW7 2AZ

E-mail: dpo@imperial.ac.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Get in touch