Privacy Policy


Privacy Notice and Information for Data Subjects pursuant to Art. 13 and Art. 14 of the EU General Data Protection Regulation. This notice describes how we process your personal data.


If you book a hotel room with ‘The Portland Hotel’, the controller is ‘S1 Partnership Ltd’.


The address of both is The Portland Hotel, Quatre Bras, Lybster, Scotland, KW3 6BS. Please see “How do I get in touch with you” below for contact details for specific matters.


Whenever you deal with one of these companies, the ‘controller’ of your personal information will be the company that you are interacting with or with whom your information has been shared. A ‘controller’ is a company that decides why and how your personal information is processed.


Where this policy refers to “we”, “our” or “us” or “The Portland Hotel” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.


This notice applies to:

  • Bookers;
  • Guests;
  • Visitors;
  • Callers; and
  • Other customers.


And anyone contacting, visiting or using our:

  • Website;
  • Facebook sites
  • LinkedIn sites
  • Twitter sites
  • Instagram sites
  • Newsletter
  • Free To Book Reservation Cente.

Summary of the purposes for processing your personal data and the legal basis for doing so:

  • We process personal data to make, amend and administer room bookings, provide hotel services, process and store payment details and provide other products and services (such as meals and car parking). We also deal with enquires, gather customer feedback, undertake market research and direct marketing (including analysis to create profiles), in our legitimate interests to promote our business and improve our service and delivery.
  • When booking with us, we don’t ask for accessibility, dietary, health or other sensitive personal data. If you (or someone on your behalf) do provide such information to us, please be aware we may need to ask for your explicit consent. In some cases, it may be permissible for us to have such data as it is in your vital interests that we do so.
  • On our websites we use third party marketing and analytical cookies plus similar technologies are included in our marketing emails, as explained in our Cookie Notice. You can reject and block cookies in your browser settings.
  • We monitor social media to respond to comments or complaints about our business and with the permission of the platform owner we may reproduce your comments on our website, on the lawful basis of our legitimate interests.
  • In our legitimate interests, we also seek to prevent and detect crime as well as protect our business and premises.
  • In order to fulfil the above purposes:
    • we disclose your personal data to payment providers, technology providers, insurers, and other specialist professional and technical service providers and advisers, to manage your bookings, arrange payments, and provide services.
    • we may transfer your personal data outside the European Economic Area (the EU Member States plus Iceland, Lichtenstein and Norway) and, where we do this, we will use safeguards to protect your data.
  • We keep your data to enable us to fulfil our contract with you or to provide services, where required by law, to respond to a question or complaint, to obey rules about keeping records, to uphold or protect contractual or legal rights or where it is in your or another party’s vital interests or our legitimate interests. Where we process personal data on the basis of your consent, we will retain it for as long as required for the specified purpose. We also keep your data in line with any statutory limitation periods and for tax, legal or regulatory purposes.


Your rights

  • Any consent(s) you give us may be withdrawn at any time.
  • You have an absolute right to object to direct marketing (and any profiling for the purposes of direct marketing) at any time.
  • You also have the qualified right to:
    • request access, rectify, and erase your personal data;
    • object to processing for any purpose where we rely on our legitimate interests as the legal basis;
    • restrict processing; and
    • supply or transfer your personal data in a portable format.


Where you exercise any of your rights, we will process your personal data to comply with your request in accordance with our legal obligations.

  • Where we use automated decision-making, you have the right to human intervention, to add a statement, and to have the decision reviewed.


You have the right to lodge a complaint with any data protection supervisory authority, in particular, the one of the country in which you are resident, work or in which your complaint arises. For the contact details of the Information Commissioner in the UK see 


We may provide additional information during the booking and check-in process and at other points at which we collect your personal data.


If you wish to exercise your rights, please visit our Contact Us page where you will be directed to a feedback form. If you require further details of our Privacy Notice please read more below.

Type of information we collect

We currently collect and process the following information:

  • Personal identifiers such as name, email address, telephone number, home address
  • To assist in booking processes we also collect payment card details for debit/credit cards, name and billing address.
  • Website visitor statistics – this does not include individual names or personal identifiers

How we collect information

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • Booking reservations for The Portland Hotel via third party Free To Book reservation centre
  • Contact form enquiries via The Portland Hotel website
  • Social media pages such as Facebook, Twitter and Instagram
  • Google Analytics to monitor website visitor statistics

We use the information that you have given us in order to:

  • Ensure a seamless and instant booking experience
  • To excellent provide customer service
  • Market research


Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are: 

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting

(b) We have a legal obligation.

(c) We have a vital interest.

(d) We need it to perform a public task.

(e) We have a legitimate interest

How we store your personal information

Your information is securely stored in our Free To Book reservation system.

We keep personal identifier information for a period of 60 days after reservation ending. We will then dispose your information.

Your Rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at  if you wish to make a request.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wycliffe House

Water Lane




Helpline number: 0303 123 1113

ICO website: