COVID-19 and health
Nothing matters more to us than the health and wellbeing of our members, service providers and team.
Our priority is to deliver an exceptional experience in the best conditions so you can focus on enjoying these special moments fully.
This notice supplements our privacy notice. It gives specific details about how we deal with personal information in light of COVID-19.
Due to the current public health situation, the venues partnering with HedonX may temporarily collect additional sensitive information from customers, including health or biometric data. They always treat the information collected from customers, in particular health and biometric data, with the highest standards of care and in line with all applicable legal requirements and guidelines from public authorities.
HedonX complies with the EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018 and all its amendments, any other legislation relating to personal data and all other local or national legislations and regulatory requirements in force at any given time which apply to us.
In response to the current situation with COVID-19, we have decided to maximise guests’, staff and partner’s security with the implementation of additional practices. The selection of locations corresponds to the highest standards in terms of cleanliness and luxury services including exceptional protocols on sanitisation.
Kindly support the communities’ efforts by practising social distancing, wearing face masks in public areas and respecting local regulations.
In coordination with venues and partners, we have implemented precautionary measures to ensure the health and safety of all our members. These practices may include:
- Temperature monitoring for guests and staff.
- Safe distancing measures throughout venues, including managing spaced seating in restaurants and bars, and limiting guest numbers in public areas.
- Elevation of cleaning standards to ensure all areas are consistently and continuously sanitised and hand sanitiser gels made available in all public spaces.
- A la carte offerings only in restaurants, with no buffets or shared dishes.
On top of these measures, the ones already in place in our carefully selected venues will take precedence.
Members, staff or employees showing any symptoms of COVID-19 are invited to reach out to us at email@example.com. We also ask you to follow the most up-to-date NHS and government guidance. Please be reassured that we will not share your identity with any other guests or members beyond the boundaries set by law in order to prevent the raise of COVID-19 infections.
What personal data can be collected by the venues or service providers?
Depending on the situation, the following information may be collected:
- Your name and contact details.
- When authorised by local regulations or when you agree, your temperature may be taken before you are given access to services/premises or to a public area. On such occasions, the service provider does not record this information, which is deleted immediately, unless the readings are not within acceptable levels. In this case, they may deny access and retain the data in order to demonstrate that their denial was reasonable.
- With your agreement or when required by local regulations, the service provider may collect your name, contact details, date, time and location of your presence in the premises they manage for contact tracing purposes. If you notify them that you have been tested positive, they will not record this information but only the date, time and location of the risk in order for them to be able to notify the relevant customers that may have been exposed, unless otherwise required by law.
- Your medical insurance information, as required by tourism and travel regulations.
Why is collect personal data collected?
Depending on the situation, your personal data will be collected and processed for the following purposes:
- To check body temperature prior to giving access to public areas and premises and to protect the health and safety of customers, staff, contractors and suppliers;
- To record attendance in certain premises, in order to notify customers if they have been exposed to a risk and to recommend self-isolation;
- With your permission, to record if you have a particular risk to your health so they can take any additional measure appropriate to ensure your safety;
- To record your medical insurance information as required by health regulations.
What are their legal grounds to collect and process your personal data?
Venues and service providers rely on the following legal bases to collect and process your personal data:
- Your explicit consent.
- To perform the contract you have with us;
- To comply with a legal obligation, for example when they are required to collect and process your information because they have a legal requirement to do so in some jurisdictions;
- To protect your vital interest. When required by the circumstances, they may process your data to protect your vital interests or the vital interests of other individuals;
- Their legitimate interests. They may process your data because it is in their legitimate interests to do so, or the legitimate interests of others.
Special category data
Depending on the circumstances,venues and service providers rely on the following legal bases to collect and process your health information:
- Your explicit consent;
- To comply with a legal obligation, for example when they are required to collect and process your information because they have a legal requirement to do so in some jurisdictions, in particular to protect and safeguard public health;
- To protect your vital interests, when you are not legally or physically able to give consent.
Who are they sharing your personal data with?
Your data will not be shared with third parties other than as documented in our regular privacy notice. However, in some circumstances, your data may be shared with:
- Public authorities, in particular health authorities, if there is a legal obligation to do so;
- Their providers, including qualified health professionals in line with local regulations,
They will not share your data outside of the European Economic Area (EEA) except when:
- It is necessary to perform your contract with us (for instance, because you are travelling outside the EEA);
- They have the legal obligation to do so.
How long do they keep your data for?
Venues and service providers will endeavour to record your personal data, especially your health data, only for the time strictly necessary for the purposes set out in this privacy notice. This includes the following periods:
- For the time of your tour or travel;
- 15 days to one month after your visit to the premises, unless a longer period is required by law;
- For as long as necessary to comply with legal obligations, contractual requirements or the establishment, exercise or defence against legal claims;
Your personal data will be deleted/destroyed immediately after the relevant retention period above is reached.
How is your data protected?
The venue and service provider will always collect and process your data, in particular health information, with due care and they will keep this data separate from their other regular business processing activities.
The information you share with them under the scope of this Privacy Notice will be secured by additional technical and organisational measures and only staff required to see this information will be able to access it on a “need-to-know” basis.
Digital records will be kept in encrypted and separate databases or folders with strict access controls in place.
To withdraw consent to the processing of your personal data, where applicable, please contact the partner venue or firstname.lastname@example.org.
It is understood that there is currently a major focus on the COVID-19 virus as health is always one of the fundamental elements and a pillar to our well-being.
Taking care of our environment, body, and soul is at the core of our priorities.
We are looking forward to welcoming you
LAST UPDATED: 03 March 2021