RAD Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared both offline and online. We respect and value the privacy of everyone who visits any one of our websites or venues.

Our websites (“our site”) are:

• carlton-prestwick.com
• dalmenypark.com
• hetlandhallhotel.com
• lochside-hotel.com
• radstonehotel.com
• royalhotelcumnock.com
• radhotelgroup.com
• rad-rewards.com

Our venues(“our venue”) are:

• Carlton Hotel, Ayr Road, Prestwick
• Dalmeny Park Hotel, Lochlibo Road, Barrhead
• Hetland Hall Hotel, Carrutherstown, Dumfries
• Lochside House Hotel Lodges and Spa, New Cumnock
• Radstone Hotel, Ayr Road, Larkhall
• Royal Hotel, Glaisnock Street Cumnock

We will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our site. If you do not accept and agree with this Privacy Policy, you must stop using our site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

2. Information About us
   1. Our site is owned and operated byRAD Ltd, a limited company registered in Scotland under company number SC157649, whose registered address is 27 Barony Road, Auchinleck, East Ayrshire, KA18 2LL.
   2. Our VAT number is 353669330
   3. Our Data Protection Officer is Stephen Schendel and can be contacted by email at privacy@rad.ltd.uk or by telephone on 01290 805011 option 2, or by post at 1 Glaisnock Street, Cumnock, East Ayrshire, KA18 1BP.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our site. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights
   1. As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

1. 1. 1. The right to be informed about our collection and use of personal data;
      2. The right of access to the personal data we hold about you (see section 12);
      3. The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
      4. The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
      5. The right to restrict (i.e. prevent) the processing of your personal data;
      6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
      7. The right to object to us using your personal data for particular purposes; and
      8. Rights with respect to automated decision making and profiling.

1. 2. If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
   3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do we Collect?

Depending upon your use of our site, we may collect some or all of the following personal data (please also see section 13 on our use of Cookies and similar technologies):

1. 1. name
   2. business/company name
   3. contact information such as email addresses and telephone numbers
   4. geoographic information such as address and post code
   5. demographic information such as date of birth and gender.

6. How do we use Your Data?
   1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
   2. Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
      1. Providing and managing your Account;
      2. Providing and managing your access to our site;
      3. Supplying our products and services to you (please note that we require your personal data in order to enter into a contract with you);
      4. Personalising and tailoring our products and services for you;
      5. Replying to emails from you;
      6. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing marketing@rad.ltd.uk or by managing your preferences through the link on each marketing e-mail sent.);
   3. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
   4. You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
   5. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
      1. Personal data obtained for the purposes of buying one of our products or services will be retained for no longer than one year after you cease to become a customer of RAD Ltd.
      2. Personal data will be retained for marketing purposes for as long as we have your consent to hold such data. You can remove permission for this at any time.

7. How and Where Do we Store Your Data?
   1. We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
   2. Your data will be stored by RAD Ltd and the following partners:
      1. Guestline – Property management service provider. This partner stores and processes all guest data for stays and events at our venues.
         1. This data is held remotely from RAD Ltd in the providers Data Centre.
      2. ResDiary – Restaurant diary service provider. This partner stores and processes customer data for anyone who has dined at one of our venues.
         1. This data is held remotely from RAD Ltd in the providers Data Centre.
      3. VoucherCart – Online gift voucher service provider. This partner stores and processes customer data to facilitate the sale and redemption of electronic gift vouchers.
         1. This data is held remotely from RAD Ltd in the providers Data Centre.
      4. BlueRunner Solutions – Customer loyalty and gift card solution provider. This partner stores and processes customer data for members of the RAD Rewards loyalty scheme. They also store and process data for customers who have purchased a physical gift card from a venue.
         1. This data is held remotely from RAD Ltd in the providers Data Centre.
   3. Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.

8. Do we Share Your Data?
   1. We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods or services, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
   2. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
   3. In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If our Business Changes Hands?
   1. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.
   2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

10. How Can You Control Your Data?
    1. In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
    2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service 4 (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information
    1. You may access certain areas of our site without providing any data at all.
    2. You may restrict our use of Cookies.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at privacy@tms-scotland.com, or using the contact details below in section 14.

13. Our use of Cookies
    1. Our site does not currently use Cookies. Our policy will updated immediately if this changes in the future.

14. Contacting us

If you have any questions about our site or this Privacy Policy, please contact us by email at privacy@rad.ltd.uk, by telephone on 01290 805011 option 2, or by post at 1 Glaisnock, Cumnock, East Ayrshire, KA18 1BP. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

15. Changes to our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check our site regularly to keep up-to-date.