This page brings together Ashford Castle's legal policies, corporate disclosures, and important notices. Here you can access information relating to your use of our website and services, including our terms and conditions, privacy and cookie policies, accessibility information, and our Gender Pay Report.
Red Carnation Hotels (UK) Limited and the companies in our group (we) are committed to protecting and respecting your privacy.
The new data protection legislation, the General Data Protection Regulation 2016 (the “GDPR”), is effective from 25th May 2018. This new legal framework builds upon existing legislation and introduces new and enhanced obligations and responsibilities upon all companies who hold or use personal information inside the European Union and/or use such information for a European citizen. We have updated our policies to reflect the new conditions.
This policy (together with our booking terms and conditions and cookie policy any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This privacy policy applies to the Red Carnation Hotel Group, encompassing all establishments within the Red Carnation Hotel Group Ltd (hereafter referred to as "we," "us," or "our"). The Red Carnation Hotel Group includes The Milestone Hotel & Residences, The Rubens at the Palace, Hotel 41, The Egerton House Hotel, The Chesterfield Mayfair, The Montague on the Gardens, Summer Lodge Country House Hotel & Restaurant, The Acorn Inn, Ashford Castle, The Lodge at Ashford Castle, The Old Government House Hotel & Spa, Hotel d'Angleterre, 100 Princes Street, Bushmans Kloof Wilderness Reserve & Wellness Retreat, The Twelve Apostles Hotel and Spa, The Oyster Box, and Xigera Safari Lodge.
We are registered under the laws of the State of Guernsey, with incorporation number CMP 62944. Our registered office is located at Travel House, Rue Du Manoir, St Peter Port, Guernsey, GY1 2JH. This privacy policy outlines our commitment to protecting your personal data.
This privacy policy has been adopted by all the legal entities that manage and operate Red Carnation Hotel Group around the world. A complete list of the entities, and additional information relevant to Red Carnation Hotel Group processing of personal information can be accessed here.
This privacy policy provides insight into how we handle personal information pertaining to individuals we engage with, such as customers and website users. It's essential that you review this policy alongside any other privacy notices we may issue during personal data collection and processing instances. By doing so, you gain a comprehensive understanding of how and why we utilise your data. Please note that this privacy notice complements other notices and is not intended to supersede them.
Examples of who this policy covers:
We include in this privacy policy personal data we process relating to:
When we are data processors
Please note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, YOU should look to that third party and its privacy policy, who will be answerable for how we process that personal data on When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
We will only use your personal information for the original purpose we collected it for. If we need to use it differently, we will make sure the new use is still related to the original one. If you have questions about how the new use relates to the original one, feel free to ask us for clarification.
Sometimes, we may need to use your personal information for additional purposes. In these cases, we will try to let you know in advance and seek your consent if necessary. For example, if you provided us with information for a booking, we might also use it for things like analysing customer trends or improving our services.
We will use aggregated data analysis to gain insights from your personal information without directly identifying you. This type of data isn't considered personal under the law because it doesn't identify individuals.
However, if we combine this aggregated data with your personal information in a way that does identify you, we'll treat it as personal information and handle it in accordance with UK and other relevant global data privacy laws.
Personal Identifying Information
This includes details like your full name, mailing address, email address, phone number, social media account identifiers, profile pictures, and any publicly available data or information provided by linking your social media and loyalty accounts.
Demographic Information and Significant Dates
This category covers data such as gender, language preferences, nationality, birthdays, anniversaries, and any other special occasions.
Government-Issued Identification
This pertains to documents like passports, visas, or any other form of government-issued identification, including the personal data contained within these documents.
Financial Information
This includes credit card, debit card, or other payment details provided during transactions.
Loyalty Program Details
Information related to membership or participation in loyalty programs, co-branded payment card details, and affiliations with travel partner programs.
Travel Details
Information about previous stays, interactions, purchases, special requests, travel itineraries, tour group data, activities, and employer details for business-related bookings.
Claims Data
This covers details such as insurance information, emergency contacts, complaints, and employment information for worker's compensation claims.
In certain circumstances, we may also collect:
Information about Family Members and Companions this includes the names and ages of children or companions.
Biometric Data Any data related to biometrics, such as fingerprints or facial recognition.
Images, Videos, and Audio Data
This involves recordings of your voice (e.g., for quality assurance during customer service calls), footage from security cameras in public areas of our properties, and recordings from body-worn cameras used by our security personnel.
Preferences
We may also gather details about your "Stay Preferences" to enhance your current and future experiences with us. This includes information about your interests, likes and dislikes about our services, dietary requirements, and other personal needs. Additionally, we may collect "Personal Preferences," which encompass details like significant anniversaries, preferred activities during your stay, hobbies, and details about your travel companions. If you provide Personal Data about others to us or our Service Providers (e.g., when making a reservation for someone else), you confirm that you have the necessary authority to do so, and you allow us to use the data in accordance with this Privacy Statement.
We collect personal information from you only under the following lawful bases:
Consent: We process your personal information only with your explicit consent, such as when you opt in to receive marketing communications.
Legal Obligation: We process your personal information when we have a legal obligation to do so, such as fulfilling financial and tax obligations based on your transaction history.
Performance of a Contract: We process your personal information when it is necessary to fulfil a contract with you, such as managing bookings, processing payments, or creating an account as requested by you.
If we request personal information to comply with a legal requirement or to perform a contract, we will clearly indicate this at the relevant time and inform you whether providing the information is mandatory, along with the potential consequences of not doing so.
Legitimate Interest: We process your personal information when it is in our legitimate interests and does not override your rights. In certain countries and regions, we may rely on legitimate interests to operate or improve our platform, communicate with you, verify security when you contact us, respond to queries, undertake marketing activities, or potentially detect or prevent illegal activities. We carefully balance our use of your personal information against your rights on a global scale.
We also collect other data that does not identify you:
Cookies
Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device. Cookies help us to provide important features and functionality on our websites and we use them to improve your customer experience. Please see our separate Cookie Notice here.
How we collect data from you:
We gather personal information and other data from other companies for various reasons outlined in this Privacy Statement. This includes tailoring services, communication, loyalty programs, and meeting business objectives.
On-Property and/or Travel Providers:
Your personal information and other data may be collected from various outlets at our properties, such as spas, restaurants, and concierge services. Online Services login to access third-party services, we collect personal information and other data. This includes partners in airlines, car rentals, and social media platforms.
Promotional Activity:
We collect personal information and other data from third parties offering promotions such as sweepstakes, contests, or special offers.
Other Sources & Service Providers
Personal information and other data are gathered from various third-party sources including public databases, joint marketing partners, financial service providers, and online travel agencies.
Online Services:
Interaction with our Online Services, including browsing, reservations, purchases, communications, social media engagement, and participation in surveys or promotions, leads to the collection of personal or other data.
Customer Support Centres
Personal information is collected when making reservations via phone, email, fax, or online chat services, and these interactions may be recorded for quality assurance and training purposes.
Internet-Connected Devices
Personal and other data may be obtained from internet-connected devices in our properties, such as smart home assistants, to tailor accommodations and enhance guest experiences.
Minors
Red Carnation Hotel respects the privacy of individuals under the age of majority in their respective jurisdiction. We do not knowingly collect, disclose, or sell personal information of minors without permission from a parent or guardian.
Closed Circuit Television (CCTV)
At Red Carnation Hotel properties, we employ closed circuit television (CCTV) and other security measures to safeguard our staff, guests, and visitors. These measures may capture or record images in public areas, as well as information related to your location while on our properties (via keycards and other technologies). This is done in accordance with applicable laws aimed at protecting the safety and security of everyone on our premises. We retain CCTV footage in alignment with our data retention policies, ensuring it is kept for the duration necessary to fulfil its intended purpose or as mandated by law. You may have the option to request access to CCTV images within the timeframe specified by applicable law and as permitted by law.
We may contact you directly to inform you about our products, services, and promotions that we think might interest you. This involves recognising you as a customer, understanding your preferences, and customising content and ads just for you. We use various methods for direct marketing, including text messages, phone calls, social media targeting, direct mail, web ads, and in-app messages.
We do not use or reveal your personal data for direct marketing unless:
If you no longer wish to receive direct marketing, you can manage your communication preferences on your online account or unsubscribe using the link provided at the end of each electronic communication.
In addition to data protection laws, we may also need to follow additional rules governing direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. "Direct marketing" refers to marketing material or advertising directed at a specific individual.
We'll use your personal data to send you marketing information (including ads and promotions) about travel services:
We'll only send you marketing information about the categories of travel services you've chosen. We'll also only contact you in the manner you've agreed to (e.g., email or SMS).
Sometimes, we may share your contact details (like name, email address, postal address, telephone number, mobile number, fax number, and preferences) with:
Advertising
We may provide advertisers with general information about how our websites are used. This information is usually anonymous and does not identify individual users.
Marketing with Your Consent
We will only use your personal information for marketing purposes if you have given us your consent. You can withdraw your consent at any time. We'll make sure you have clear options for opting in or out of marketing communications.
Withdrawing from Direct Marketing
You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”
When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.
You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.
We transfer your personal data to third parties in the following circumstances:
We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;
Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.
Suppliers Of Travel And Other Services
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.
Public Forums Etc.
Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.
Legal Requirements
We may supply personal data to a government authority or regulator where required to:
We may disclose your personal data where otherwise required by or permitted by law.
Business Customers who are Businesses (Not Individuals)
If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
Business Acquirers
If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.
How Third Parties Will Handle Your Personal Data
Where we provide your personal data to a third party one of the following two circumstances will apply:
Processing on Our Behalf
In some cases, your personal data may be held and otherwise processed by others on our behalf. We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy. The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.
Processing on Their Own Account
In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party, and they will provide their privacy policy to you.
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area ('EEA') and the United Kingdom.
We will only send your personal data outside the EEA and the United Kingdom to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA and the United Kingdom. You can find out about what adequate safeguards these are by contacting us using the details provided compliance@rchmail.com of this privacy notice.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Unfortunately, transmission of information over email is not secure, and if you submit any information to us over the internet by email, we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this, or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on the Information Commissioner Office website here.
To exercise any of your rights below, please send your request via email to compliance@rchmail.com.
You may request the following information be provided to you:
We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.
The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive. We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
Rectification
You have the right to have your personal data amended if it is inaccurate or incomplete.
Right to Object
You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.
Right to Request Access
You have the right to request access to the information we hold about you.
Erasure
You have the right to have your personal information deleted or removed in the following circumstances:
When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.
We have the right to refuse to act on a request of erasure if the data is necessary for:
Right to Receive a Copy
You have the right to receive your personal data which you have provided to us, in a structured, commonly used, and machine-readable format and to transmit those data to another controller, when:
Restrict Processing
You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:
Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise, or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so. We will inform you before the restriction of processing is lifted.
Right to Withdraw Your Consent
You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.
Right to Lodge a Complaint with a Supervisory Authority
We adhere to data protection laws regulated by various supervisory authorities worldwide. For specific regions, these include:
Geneva, Switzerland: Office of the Geneva Data Protection Authority (GDPA)
Guernsey: Office of the Data Protection Authority (ODPA)
Ireland: Data Protection Commission (DPC)
South Africa: Information Regulator (South Africa)
United Kingdom: Information Commissioner's Office (ICO)
Each supervisory authority has the authority to compel compliance with data protection laws and impose fines for non-compliance. We encourage you to contact us first with any complaints or concerns. You can find our contact details in Section 16 of our privacy notice. If you reside in the European Economic Area and are dissatisfied with our handling of your request or believe we have violated applicable data protection laws, you may also lodge a complaint with the competent supervisory authority in your country or market of residence.
Where a guest is aged 16 or 17 and stays independently at The Rubens at the Palace, Hotel 41, The Chesterfield Mayfair, The Egerton House Hotel, The Milestone Hotel & Residences, or The Montague on the Gardens, we will normally treat them as being able to exercise their own data protection rights. If a request is received from a parent or guardian requesting access to that guest’s personal data, we will usually require the guest’s consent before disclosing that information, unless exceptional circumstances apply, or we are required to do so under applicable data protection law. In assessing these requests, the age and maturity of the guest will be considered, and the guidance provided by the ICO.
Period for Retaining your Personal Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.
Changes to this privacy policy
We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.
Contacting Us
If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail to compliance@rchmail.com or by post to Red Carnation Hotels Marketing, 14 Grosvenor Place, London, SW1X 7HH.
We are pleased to present our Gender Pay Gap Report for 2024/2025. Highlighting gender pay disparities, both within our organisation and in the wider sector, remains essential. By analysing our data with care and transparency, we ensure our culture consistently champions equality of opportunity, where every colleague feels respected, valued, and empowered to thrive.
Our team is proudly multinational, with colleagues from up to 35 nationalities contributing their skills, perspectives, and experiences. Our people are our greatest strength, and our Learning & Development resources are designed to nurture potential - providing the tools, feedback, and support needed to grow and excel.
Together, we remain focused on continuous improvement - removing barriers, building equitable systems, and sustaining a culture where everyone can do their best work.
