Privacy Policy

This Privacy Policy explains how TTM Media Ltd ("we", "us", "our") collects, uses, stores, and protects personal data in connection with the website hotelierschoice.com ("the Website"). We take our obligations under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 seriously, and this policy is designed to give you clear, honest information about how your data is handled.

1. Data Controller

The data controller responsible for the Website is:

TTM Media Ltd 20-22 Wenlock Road
London, England
N1 7GU
United Kingdom
support@luxury-reviews.com

2. What Data We Collect

We collect the following categories of data when you use the Website:

• Usage data: Information about how you interact with the Website, including pages visited, time spent on pages, referring URLs, browser type, operating system, and device type. This data is collected automatically via analytics software.
• Cookie data: Information stored in cookies and similar tracking technologies (see Section 5 for full details).
• Contact data: If you contact us by email, we collect the information you include in your message, including your name and email address.
• Technical data: IP address (anonymised where possible), session identifiers, and similar technical identifiers used for security and performance monitoring.

We do not collect or process any special categories of personal data (as defined under Article 9 of the UK GDPR), and we do not operate user accounts or collect payment information directly.

3. How We Use Your Data

We use the data we collect for the following purposes:

• Website analytics: To understand how visitors use the Website, identify popular content, and improve our guides. Our legal basis is legitimate interests (Article 6(1)(f) UK GDPR).
• Responding to enquiries: To respond to messages sent to us via email. Our legal basis is the performance of a task carried out in the public interest or the exercise of official authority, or legitimate interests.
• Security and fraud prevention: To monitor for and protect against malicious activity, spam, and technical attacks. Our legal basis is legitimate interests.
• Legal compliance: To comply with applicable laws and regulations, including data protection law and tax obligations. Our legal basis is compliance with a legal obligation (Article 6(1)(c) UK GDPR).

4. Legal Basis for Processing

Where we process personal data, we do so on the following legal bases under the UK GDPR:

• Legitimate interests (Article 6(1)(f)): For analytics, security, and responding to enquiries, where our interests do not override your rights and freedoms.
• Consent (Article 6(1)(a)): For non-essential cookies and tracking (e.g., analytics, affiliate tracking), where we seek your consent via our cookie notice.
• Legal obligation (Article 6(1)(c)): Where processing is necessary to comply with applicable law.

5. Cookies and Tracking Technologies

The Website uses cookies and similar technologies. A cookie is a small text file placed on your device by your browser when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Website to function. These cannot be disabled. They include session cookies for security and performance.
• Analytics cookies (Google Analytics): We use Google Analytics to collect anonymised data about how visitors use the Website. Google Analytics may set cookies such as _ga, _gid, and _gat. We have configured Google Analytics with IP anonymisation enabled. These cookies are only placed with your consent.
• Affiliate tracking cookies: When you click an affiliate link (e.g., to Booking.com, Hotels.com, or other travel platforms), the affiliate network may place a tracking cookie on your device to attribute any resulting booking to us. These cookies are set by third parties and are subject to their own privacy policies. They are only activated when you actively click a link.

You can control cookies through your browser settings and withdraw consent at any time. Most browsers allow you to refuse all cookies or to indicate when a cookie is being set. Disabling analytics cookies will not affect your ability to use the Website. For instructions on managing cookies in your specific browser, visit allaboutcookies.org.

6. Third-Party Services

We work with the following third-party services that may process data in connection with your use of the Website:

• Google Analytics (Google LLC): Website traffic analysis. Google processes data in the United States under the EU-US Data Privacy Framework and Standard Contractual Clauses. Google Privacy Policy
• Booking.com (Booking.com B.V.): Affiliate partner. When you click a Booking.com link on the Website and make a booking, Booking.com may process your personal data in accordance with their own privacy policy. Booking.com Privacy Policy
• Other affiliate networks: The Website may include links to Hotels.com, Expedia, and other travel platforms. These platforms may process data in accordance with their own privacy policies when you click through and interact with their services.
• Hosting and infrastructure providers: Our Website is hosted on infrastructure provided by third-party hosting companies. These providers process data on our behalf as data processors and are bound by appropriate data processing agreements.

We have no control over, and accept no responsibility for, the privacy practices of third-party websites linked from the Website. We encourage you to review the privacy policies of any third-party services you interact with.

7. Your Rights Under UK GDPR

As a data subject under the UK GDPR, you have the following rights:

• Right of access: You have the right to request a copy of the personal data we hold about you (a Subject Access Request).
• Right to rectification: You have the right to request that inaccurate or incomplete personal data we hold about you is corrected.
• Right to erasure: You have the right to request that we delete personal data we hold about you in certain circumstances (the "right to be forgotten").
• Right to data portability: Where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests, or where data is processed for direct marketing.
• Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at support@luxury-reviews.com. We will respond to all requests within one calendar month. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:

• Analytics data: Retained for up to 26 months (as configured in Google Analytics), after which it is automatically deleted.
• Email correspondence: Retained for up to 3 years, unless a longer retention period is required for legal or business reasons.
• Technical logs: Typically retained for 30–90 days for security and performance monitoring purposes.

9. International Data Transfers

Some of the third-party services we use (including Google Analytics) transfer data outside the United Kingdom. Where such transfers occur, we ensure they are subject to appropriate safeguards, such as Standard Contractual Clauses approved by the UK Information Commissioner, or adequacy decisions made by the UK Government.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These measures include HTTPS encryption, access controls, and regular security reviews. No method of transmission over the internet or electronic storage is completely secure; while we take our security obligations seriously, we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of the page. We encourage you to review this page periodically. Continued use of the Website after any changes constitutes acceptance of the updated policy.

12. Contact Us

For any questions about this Privacy Policy, or to exercise your data rights, please contact our team at support@luxury-reviews.com.