Policy version: [05/04/2023]
https://www.nubreedhotels.com/ & www.eventbeds.net (our websites) are provided by NuBreed Hotels Limited
(‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website and our Platform, meaning
we are the organisation legally responsible for deciding how and for what purposes it is used.
information on who we are and how and why we collect, store, use and share any information relating to you
(your personal data) in connection with your use of our website and Platform. It also explains your rights in
relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Given the nature of our website and Platform, we do not expect to collect the personal data of anyone under 13
years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website or Platform, please let us know so that we can delete that data.
What this policy applies to
For the purpose of this policy, Platform means EventBeds, a software application including the data supplied
with the software and any updates or supplements to it which allows a customer to make a booking with a third
party hotel provider and allows event organisers to upload events.
Throughout our website and Platform we may link to other websites and platforms owned and operated by
certain trusted third parties to make additional services available to you such as ratings and reviews in relation to
accommodation services we offer . Those third party websites and platforms may also gather information about
you in accordance with their own separate privacy policies. For privacy information relating to those third party
websites and platforms, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website
and/or use of our Platform. We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together as follows:
• Identity data includes your name, title, date of birth and company details
• Contact Data includes billing address, delivery address, physical address(es), postcode, email address
and telephone numbers
• Financial Data includes bank account details and your debit/credit card information
• Transaction Data includes details of the locations where you have stayed, including the date of arrival
and departure and the cost
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time
zone setting and location, browser plug-in types and versions, operating system and platform, and other
technology on the devices you use to access our website or Platform
• Profile Data includes your username, purchases or orders made by you, your interests, preferences and
• Usage Data includes details of your use of our website or Platform
• Marketing and Communications Data includes your preferences in receiving marketing from us and
our third parties and your communication preferences
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated
Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as
We do not collect any special category personal data.
How your personal data is collected
We may collect personal data from you in the following ways:
• Direct interactions. You may give us your Identity, Contact and Financial Data by registering as a
User on our Platform, contacting us (including via email and our chat function), sending us feedback,
or purchasing services via our website or Platform.
• Automated technologies or interactions. As you interact with our website or Platform, we will
automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and
• Information we receive from other sources including third parties. We will receive personal data
about you from various third parties as set out below:
• from analytics providers such as Google based inside the UK; and
• from event organisers based inside the UK.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a
• for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this
is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate
interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
We will use your personal data to send you updates (by email, text message, telephone or post) about our
services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we
use your personal data’). This means we do not need your consent to send you marketing information. If we
change our marketing approach in the future so that consent is needed, we will ask for this separately and
You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link
in emails we send to you.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the
future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other
organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing
purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver our services to you, eg payment service providers such as Stripe,
and accommodation providers which you have chosen to stay with which may include accommodation
wholesalers known as bed banks
• other third parties we use to help us run our business, eg website hosts, such as Microsoft Azure and
website analytics providers
We only allow those organisations to handle your personal data if we are satisfied they take appropriate
measures to protect your personal data.
We may also share personal data with:
• our professional advisors (such as lawyers and other advisors), in which case the recipient of the
information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and
regulatory obligations; and
• other parties that have or may acquire control or ownership of our business (and our professional
advisers) in connection with a significant corporate transaction or restructuring, including a merger,
acquisition, asset sale, initial public offering or in the event of our insolvency. Usually, information
will be anonymised, but this may not always be possible. The recipient of any of your personal data
will be bound by confidentiality obligations.
How long your personal data will be kept
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, regulatory or reporting requirements. We may retain your
personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
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, regulatory or other requirements.
In some circumstances we will 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
Transferring your personal data out of the UK
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases, we
will comply with applicable UK laws designed to ensure the privacy of your personal data.
We will transfer your personal data to our service providers located outside the UK in the European Economic
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
• the UK government has decided the particular country ensures an adequate level of protection of
personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies
for you, or
• a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation. In the
event we cannot or choose not to continue to rely on these mechanisms at any time we will not transfer your
personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception
provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to
transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
inaccessible or not function properly. For more information about the cookies we use, please see
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You
have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you
provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to comply with your request of erasure
for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing
of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this
will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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
could refuse to comply with your request in these 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 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or
accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
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.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to
contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in the UK.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint
or by telephone: 0303 123 1113.
inform you, for example by including a prominent link to a description of those changes on our website and our
Platform for a reasonable period or by other means, such as email.
How to contact us
Individuals in the UK
information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are:
Email address: email@example.com
Postal Address: c/o NuBreed Hotels – Belgravia House, 115 Rockingham Street, Sheffield, S1 4EB