Six Senses Place London

Privacy Statement

Version date: 19 May 2025

1. Who we are

This privacy statement is issued by IHG Hotels Limited which is a company incorporated in England & Wales (number 08055224) with its registered office at 1 Windsor Dials, Arthur Road, Windsor, Berkshire SL4 1RS (referred below to as 'Six Senses Place London', 'we', 'us', or 'our').

2. Purpose and scope of this privacy statement

This privacy statement provides information on how we collect and manage personal information that you provide relating to you or other individuals when, as applicable, you access our website, use Six Senses Place London, receive any of the services that we offer or where you provide your information to us for another purpose.

Please note that this privacy statement only relates to information collected and processed by Six Senses Place London. Where you contact or use any Six Senses Place located elsewhere, a separate privacy statement will apply to information collected in relation to that specific location.

3. How to contact us

If you have any questions about this privacy statement or would like to exercise your legal rights as referred to below, please contact us at privacyoffice@ihg.com or by writing to InterContinental Hotels Group plc, Attn: Privacy Office, 1 Windsor Dials, Arthur Road, Windsor, Berkshire, SL4 1RS, United Kingdom.

4. Changes to this privacy statement

We keep this this privacy statement under regular review and may update it from time to time, so please check that you have seen the latest version.

5. Information we collect, how we use it and the legal basis for processing

Type of data	Lawful basis	Purpose of processing
Identification data: When you register to join Six Senses Place London or contact us directly (via the phone, online or in person) we will collect your name, nationality, date of birth, job title, email address, phone number and address (if applicable) and your payment details.	Performance of a contract	We collect this in order to take steps to enter into a contract with you and allow you to make use of the Six Senses Place London facilities.
	Legitimate interest	When you contact us either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query or fulfil your request. We also need to use such data to administer and manage our member database and deal with any membership issues.
Marketing data: we will collect your name, email address, cookie, IP address to provide you with our news updates in line with any preferences you have told us about.	Consent	When we send you news updates and information about events or offers because you have opted-in to receive them, we rely on your consent to continue send these to you. You can unsubscribe from receiving further marketing communications at any time by following the unsubscribe link in such communications or by emailing us at privacyoffice@ihg.com.
	Legitimate interest	To optimise our website and improve our services and product offering.
Cookies and other tracking technologies: we will collect cookies and certain other tracking information about your device when you access and use our website.	Consent/Legitimate interest	We use this information to improve our website and to better understand how people use it and where they come from. You will find more details on the information we collect through cookies and other tracking technologies in our Privacy Statement (www.sixsenses.com/en/corporate/privacy#cookies-and-other).
Financial data: we will collect credit card details, bank account details.	Performance of a contract	To allow you to set up and pay for your membership, treatments, food and beverage and other items you wish to purchase at Six Senses Place London.
Analysis: we may collect information about your visit to Six Senses Place London including the particular treatments you booked or any products or services you purchased.	Legitimate interest	To enable us to understand our members and guests better and offer more personalised services based on your indicated needs and preferences.
Health data: we may collect and keep some information about your health that you disclose to us (for example, existing health conditions, injuries or other physical issues and allergies that we need to be aware of) when you register to join Six Senses Place and when you fill out a registration form before using our facilities or booking treatments with us.	Consent	We only use your health data where you have provided your explicit consent, and we only use this information to the extent needed to ensure that we can provide services with appropriate safeguards in place for your wellbeing. You can withdraw consent to use your health data at any time (see paragraph Errore. L'origine riferimento non è stata trovata., below), although this may mean that we can no longer provide certain treatments or other services to you.
	Vital interests	We may very occasionally have a need to use your health data and provide this information to first aid staff, paramedics or medical professionals who provide treatment which is in your vital interests, and you are unable to provide informed consent (for example, if you suffer from a severe allergic reaction or you lose consciousness when on our premises).

6. Data sharing and transfers

Six Senses Place London is located within the Six Senses London hotel (see https://www.sixsenses.com/en/hotels-resorts/europe/unitedkingdom/london/).

So that we can responsibly administer and manage our business, provide an effective service and comply with our legal obligations, it may be necessary to share your information with one or more of the following:

- Six Senses London to enable us to confirm your guest status if you use Six Senses Place London when staying at the hotel as well as being able to track your spending and add any payments due to your hotel bill for any services that you use. We may also share guest data to enable us or Six Senses London to provide a more seamless service to you or your other guests during your stay or during any future visits.
- Business partners and suppliers to help us perform our obligations and to enable us to provide an efficient and effective service to our members and guests.
- Subcontractors and data processors who help support our business operations, communications and technical infrastructure. For example, providers of IT systems or CCTV operators. We take all reasonable steps to ensure that any data processors we engage are only permitted process your personal information for specified purposes in accordance with our lawful instructions and under an appropriate data processor agreement.
- Our professional advisers and external agencies to establish, enforce or defend our rights or who help safeguard our business or property. We may also need to occasionally share information in order to protect our staff, members, guests or other parties. For example, we may share information with our insurers or professional advisers (lawyers or accountants) or with external organisations in order to protect ourselves from fraud, criminal activity or other threats.
- Regulatory authorities, courts or law enforcement agencies if we are under a duty to disclose or share personal information in order to comply with a legal or regulatory obligation or we need to provide information to the police or another law enforcement agency in connection with a criminal investigation.
- Buyers of our business or merger partners with whom we may have to share personal information to facilitate an acquisition or merger, although we will take reasonable steps to ensure that your information continues to be used by any acquirer or merger partner in a lawful and transparent manner for the same or similar purposes that you would reasonably expect.
- Other parties who you ask us to share personal information with, or who we inform you of from time to time in the future.

Where necessary, and subject to applicable law, we will take reasonable and lawful steps to ensure that any private or sensitive information that we share is kept confidential and subject to appropriate contractual protections.

7. Transferring your personal information

Your personal information may be transferred for processing to countries or territories outside the UK or European Economic Area (EEA) whose laws are not regarded as providing the same level of legal protection as you enjoy in the UK or EEA. Such transfers of personal information are referred to 'restricted transfers' and we ensure that when we make or facilitate a restricted transfer, it is done in a manner that complies with applicable data protection law.

For occasional restricted transfers of personal information we may rely on an exemption under data protection law that permits such a transfer to take place subject to certain conditions, for instance:

- the transfer is necessary for the establishment, exercise or defence of legal claims (including possible future claims);
- we have obtained your informed and explicit consent to make the transfer; or
- the transfer is necessary for us to take certain pre-contractual measures at your request or for the conclusion or performance of a contract between you and Six Senses Place London.

Alternatively, where restricted transfers of personal information are being made on a systematic basis, we will use the International Data Transfer Agreement approved for use by the UK data protection regulator, the Information Commissioner's Office ('ICO') or such other legally authorised mechanisms which are deemed to give individuals and their personal information adequate protection in accordance with applicable UK data protection law.

If you require further information regarding the particular measures that we use when making a restricted transfer of your personal information, please contact us.

8. Retaining your personal information

We will only retain personal information for as long as reasonably necessary to fulfil the purpose we collected it for.

Please note that we may need to retain personal information beyond the period of your membership or our relationship in order to comply with applicable legal obligations and to meet relevant tax, accounting or regulatory reporting requirements. We will also need to retain certain information regarding membership history or services that we have provided in the past in order to deal with possible future legal issues or claims.

The criteria that we use for retaining personal information will generally be determined by reference to applicable law and relevant guidance issued by the ICO or other regulatory authorities from time to time.

Personal information that we no longer need is securely disposed of and/or anonymised, so the relevant individual it relates to can no longer be identified. In some circumstances, we may use anonymised information indefinitely for statistical purposes or to improve our services.

9. Information security

We employ (and ensure that our data processors adopt) appropriate technological and operational security measures to protect the personal information that we collect or process against any unauthorised access and unlawful processing or loss.

Please note that we cannot guarantee the security of data sent to us over the internet or when you use public Wi-Fi or other communications services. We therefore strongly recommend that you take appropriate precautions, such as using a secure virtual private network, where you wish to send any personal information to us that you consider to be particularly sensitive.

10. Your rights

You have certain legal rights in relation to the personal information we process about you which are summarised below. You may:

- Request access to a copy of the personal information that we hold about you and certain other information about how we process it (known as a data subject access request).
- Request correction of the personal information that we hold about you if it is inaccurate.
- Request erasure of your personal information in certain circumstances where there is no legitimate reason for us to continue to hold or process it.
- Object to processing of your personal information in certain circumstances where we are relying on a legitimate interest which unduly impacts on your rights and freedoms.
- Request restriction of processing of your personal information in certain circumstances – for example, if there is a dispute about its accuracy.
- Request the transfer of your personal information to a third party which you initially consented to us using or where we use such information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data and in particular to send you direct marketing. However, this will not affect any processing carried out before such withdrawal and we may not be able to provide further services to you.

You will not normally have to pay a fee to exercise these rights. However, we may charge a reasonable fee or refuse to comply where a request is manifestly unfounded or excessive. The above rights may also be subject to certain legal conditions and exemptions which we will notify you of when we respond.

We may also need further information to help us verify your identity or clarify the scope of your request before we can respond. We usually respond to these legal requests within one month, although this period may be extended by an additional two months for complex requests.

If you are concerned that we have not complied with data protection law or responded appropriately to you when exercising your rights, you also have the right to make a complaint at any time to the ICO (see https://ico.org.uk/make-a-complaint/).

We would, however, appreciate the chance to deal with any privacy complaint or concern so please contact us in the first instance.

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