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Farr Bay Inn respects the privacy and security of our guests, prospective guests, customers and website visitors. This notice explains how personal information may be collected, received, used, shared and protected when you interact with Farr Bay Inn, make or manage a reservation, stay with us, use our website or communicate with us.

1. Who we are

Farr Bay Inn is operated by:

Innovating Hospitality Limited
Company number: SC752642
Farr Bay Inn
Bettyhill
Thurso
KW14 7SZ
United Kingdom

For the purposes of applicable UK data protection law, Innovating Hospitality Limited is a data controller in respect of personal information for which it determines the purposes and means of processing.

Privacy and data protection enquiries may be sent to:

reservations@farrbayinn.co.uk

2. The wider reservation ecosystem

Modern accommodation reservations can involve a number of interconnected organisations, platforms and technology providers.

Depending on how you make your reservation, information relating to your booking may pass between or be processed by Farr Bay Inn and third parties involved in the booking journey. These may include online travel agencies and booking platforms, reservation and property-management systems, payment providers, website and hosting providers, communications providers and other suppliers necessary to administer a reservation or provide our services.

For example, where a reservation is made through an online travel agency such as Booking.com, that platform may collect information directly from you and subsequently provide information required to administer your reservation to Farr Bay Inn and/or systems used in managing our accommodation.

Farr Bay Inn does not necessarily control the manner in which an independent booking platform collects or processes information before it is supplied to us. Those organisations may act as independent data controllers for aspects of their processing and have their own privacy notices.

You should therefore also review the privacy information supplied by any third-party service through which you choose to make a reservation.

3. Information we may collect or receive

Depending upon your interaction with us, we may process information including:

• your name and contact information;

• postal address;

• telephone number;

• email address;

• reservation reference;

• arrival and departure dates;

• accommodation selected;

• number and names of guests;

• booking preferences and requests;

• correspondence and communications with us;

• information necessary to process or record payments;

• transaction and payment-status information;

• information relating to cancellations, refunds or disputes;

• accessibility, dietary or other information you choose to provide where necessary to provide requested services;

• information required by law in connection with hotel accommodation;

• information associated with complaints, incidents, security matters or damage;

• technical information relating to use of our website, where applicable; and

• other information reasonably necessary to administer your reservation or provide services requested by you.

We aim to collect only information that is relevant and reasonably necessary for the purpose for which it is being used.

4. Information received from third parties

We may receive personal information about you where you have not supplied it directly to Farr Bay Inn.

This commonly occurs where you book through an online travel agency, travel provider, booking platform, travel agent or another person making a reservation on your behalf.

Information received may include your identity and contact information, reservation details, booking preferences, payment or payment-status information, communications associated with the reservation and other information necessary to administer your stay.

The source will generally be the booking platform, travel provider, booking agent, person or organisation through which the reservation was made.

5. Why we use personal information

We may use personal information to:

• create, confirm and administer reservations;

• provide accommodation and other services;

• communicate before, during and after a stay;

• process and reconcile payments, deposits and refunds;

• respond to enquiries and requests;

• manage cancellations and booking amendments;

• provide customer service;

• maintain appropriate business and financial records;

• meet legal, tax, accounting and regulatory obligations;

• protect guests, staff, our property, systems and business;

• prevent, identify and respond to fraud, misuse and security incidents;

• establish, exercise or defend legal claims;

• investigate complaints, disputes or incidents;

• maintain and improve our services and systems; and

• send marketing communications where permitted by law and subject to applicable preferences and rights.

6. Our lawful bases

Depending on the particular processing, we rely on one or more lawful bases under UK data protection law.

Contract: where processing is necessary to take steps at your request before entering into a contract or to perform our accommodation or services contract with you.

Legal obligation: where information must be processed or retained to comply with legislation, taxation, accounting, regulatory or other legal requirements.

Legitimate interests: where processing is reasonably necessary for our legitimate business interests or those of another organisation and those interests are not overridden by your rights and freedoms. These interests may include operating and protecting our accommodation business, administering reservations, preventing fraud, securing systems, handling complaints and legal claims and improving our services.

Consent: where we specifically request and rely upon your consent. Where consent is the lawful basis, you may withdraw it subject to applicable law.

Where special-category information is processed, we will only do so where an additional lawful condition permits it.

7. Hotel registration requirements

Accommodation providers are subject to statutory record-keeping requirements.

Information required under the Immigration (Hotel Records) Order 1972 is collected and retained in accordance with applicable legal requirements.

These records may be made available to persons legally authorised to inspect them.

8. Who we may share information with

Where necessary and lawful, information may be disclosed or made available to categories of recipients including:

• reservation and property-management technology providers;

• online travel agencies and booking platforms;

• payment processors and financial institutions;

• website, hosting and IT service providers;

• email and communications providers;

• professional advisers including accountants, insurers and legal advisers;

• contractors and service providers supporting our operations;

• fraud-prevention and security providers;

• law-enforcement, courts, regulators, government bodies or other authorities where required or permitted by law; and

• other organisations where disclosure is reasonably necessary to establish, exercise or defend legal rights.

We do not sell guest personal information.

Third-party organisations may act as processors on our behalf or, depending upon the circumstances, as independent controllers of personal information.

9. Booking platforms

If you book through a third-party platform, your relationship with that platform is also governed by its own terms and privacy practices.

Information may be exchanged between Farr Bay Inn, the booking platform and reservation technology used to administer your reservation.

Communications sent through platform-generated or relay email addresses may also pass through systems operated by the relevant platform.

10. Payments and payment security

Payment information may be processed using third-party payment and booking technology. We seek to minimise the amount of payment-card information directly handled or retained by Farr Bay Inn.

Guests should exercise caution if they receive an unexpected communication requesting payment or payment-card information.

If you receive a payment request that you are uncertain about, particularly through an unexpected messaging service or link, please do not rely solely upon the communication itself. Contact Farr Bay Inn independently using the contact details published on our official website so that we can verify the request.

11. Fraudulent and suspicious communications

Fraudsters may attempt to impersonate accommodation providers, booking platforms or other businesses involved in travel reservations.

Because a reservation may interact with several systems and organisations during its lifecycle, the existence of a fraudulent communication does not, by itself, establish where or how information used within that communication was obtained.

Where we become aware of suspicious activity affecting or potentially affecting guests, we may process relevant reservation and contact information for fraud prevention, security, investigation and guest-protection purposes and may contact potentially affected guests where appropriate.

We may also share relevant information with booking platforms, technology providers, financial institutions, insurers, professional advisers, law enforcement or regulators where reasonably necessary and lawful.

12. Data security

We take reasonable technical and organisational measures designed to protect personal information against unauthorised or unlawful processing and against accidental loss, destruction, alteration or disclosure.

Access to guest information should be limited to persons who reasonably require it for their duties.

No internet-connected system or transmission method can be guaranteed to be completely secure. We therefore continually consider security risks and review appropriate safeguards.

13. How long we retain information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, accounting, regulatory, operational and dispute-resolution requirements.

Different categories of information therefore have different retention periods.

Statutory hotel registration records are retained for at least the period required by applicable law.

Reservation and transaction records may be retained for longer where necessary for accounting, taxation, contractual, insurance or legal purposes.

Security and incident information is retained for an appropriate period having regard to the nature of the incident, potential claims and legal or regulatory requirements.

Information that is no longer reasonably required should be securely deleted, destroyed or anonymised where appropriate.

14. International processing

Some suppliers, booking platforms and technology providers used during a reservation journey may operate internationally or process information outside the United Kingdom.

Where Innovating Hospitality Limited is responsible for an international transfer of personal information, we will seek to ensure that an appropriate lawful transfer mechanism or safeguard is used where required by UK data protection law.

Independent booking platforms and other controllers may make their own international transfers under their respective privacy policies.

15. Cookies and website technology

Our website may use cookies and similar technologies necessary for its operation and, subject to applicable requirements, technologies used for functionality, measurement or analytics.

Where consent is legally required for non-essential cookies or similar technologies, these should not be used until the appropriate consent has been obtained.

Further information should be available through our cookie information and consent controls.

16. Your data protection rights

Depending upon the circumstances and lawful basis being relied upon, you may have rights including:

• access to personal information we hold about you;

• correction of inaccurate information;

• erasure of information in certain circumstances;

• restriction of processing in certain circumstances;

• objection to certain processing;

• data portability where applicable; and

• withdrawal of consent where processing is based upon consent.

These rights are not absolute and legal exemptions may apply.

To exercise a data protection right, contact:

reservations@farrbayinn.co.uk

We may need to take reasonable steps to verify your identity before disclosing personal information.

You also have the right to complain to the UK Information Commissioner's Office (ICO) about the way your personal information has been handled.

17. Security incidents

Where we become aware of an incident involving personal information, we will assess the circumstances and take steps considered appropriate having regard to the nature of the incident, the information involved and the potential risk to individuals.

Where applicable law requires notification to the Information Commissioner's Office or affected individuals, we will take appropriate steps in accordance with those requirements.

The existence of suspicious or fraudulent communications purporting to relate to a reservation does not automatically mean that Farr Bay Inn's own systems have experienced a personal-data breach. Any such matter will be assessed on the available evidence and, where appropriate, with relevant service providers or booking platforms.

18. Changes to this notice

We may update this Privacy & Data Protection Notice to reflect changes to our services, technology, suppliers, practices or legal requirements.

The current version and effective date will be published on our website.

19. Contact us

Questions about this notice or the way Farr Bay Inn handles personal information may be directed to:

Innovating Hospitality Limited
Trading as Farr Bay Inn
Farr Bay Inn
Bettyhill
Thurso
KW14 7SZ
United Kingdom

Email: reservations@farrbayinn.co.uk
Telephone: 01641 521 230