Policies

In line with the Payment of Wages Act 2022, please see our electronic service charge, tips and gratuities policy HERE

In line with the Gender Pay Gap Information Act 2021 , please see The Johnstown Estate gender pay gap report HERE

THE JOHNSTOWN ESTATE PRIVACY STATEMENT

The Johnstown Estate values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use, and disclose your Personal and Other Data (collectively, “Data”)

Privacy Preferences

At The Johnstown Estate, we respect your privacy and want to provide you with the options, information, and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

DATA COVERED BY THIS PRIVACY STATEMENT

This Privacy Statement describes the privacy practices of The Johnstown Estate for data that we collect:

• through websites operated by us from which you are accessing this Privacy Statement, including thejohnstownestate.com and other websites owned or controlled by The Johnstown Estate (collectively, the Websites);
• through the software applications made available by us for use on or through computers and mobile devices (the Apps);
• through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our Social Media Pages);
• through email messages that we send you that link to this Privacy Statement and through your communications with us online or in-person;
• from third parties such as Authorized Licensees, Owners and Franchisees, and Other Sources, such as public databases, marketing partners, and other third parties; and
• when you visit or stay as a guest at The Johnstown Estate, or at the lodges (Rooms and Lodges), or through other offline interactions (collectively, Property Visits and Offline Interactions).

Collectively, we refer to the Websites, the Apps, and our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.”

THE DATA WE COLLECT

At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law and serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:

•  Name
•  Gender
•  Postal address
•  Telephone number
•  Email address
•  Financial information (such as credit and debit card numbers or other payment data)
•  Language preference
•  Date and place of birth
•  Nationality, passport, visa, or other government-issued identification data
•  Important dates: birthdays, anniversaries, and special occasions
•  Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
•  Employer details (for business-related bookings)
•  Travel itinerary, tour group, or activity data
•  Prior guest stays or interactions, goods and services purchased, special service and amenity requests
•  Social media account ID, profile photo, and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we may also collect:

• Data about family members and companions, names, and ages of children
• Biometric data
• Images, video, and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions, or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” which may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship with you, and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

You can learn more about how Google uses information from sites such as The Johnstown Estate here.

COOKIES AND OTHER DATA

Personal data will be used for the personalization of ads and that cookies may be used for personalized and non-personalized advertising. We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an identified individual. To the extent Other Data reveal your specific identity or relates to an individual, we will treat Other Data as Personal Data. Other Data include:

• Your browser or device. We collect certain data through your browser or automatically through your devices, such as your Media Access Control (MAC) address, computer type (Windows or Apple), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
• Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device number. We use this data to ensure that the Online Services function properly. We may also collect mobile device advertising identifiers to enhance and personalize your experience and deliver relevant products, content, or ads to show you on our Website, Apps, or external advertising.
• Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using the Online Services, and to recognize your computer to assist your use of the Online Services. We also gather statistical cookie data about the use of Online Services to continually improve design and functionality, understand how they are used, and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html.

• Manage Cookie Preferences:
  • You can choose whether to accept cookies by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page or by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.
• Third-Party Advertising:
  • We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites, or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through the use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.
• Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services.
• We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about the use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt-out by visiting http://www.adobe.com/privacy/opt-out.html.
• Your IP Address. We collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.
• Aggregated and Segmented Data. We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.
• Precise Location-Based Services. With your consent, we may collect the precise physical location of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you chose to share the data.

HOW AND WHERE DO WE COLLECT YOUR DATA

This Privacy Statement describes the privacy practices of The Johnstown Estate for Personal and Other Data that we collect through the following:

• The Johnstown Estate. We collect Personal Data and Other Data from other companies within The Johnstown Estate for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, and accomplishing our business purposes.
• On-Property and/or Travel Providers. We may collect your Personal Data and Other Data from spas, restaurants, leisure clubs, concierges, and other outlets at our properties.
• Linked Accounts. We collect Personal Data and Other Data when you use the Online Services login to receive or register for certain third-party services. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to collect your Personal Data or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions, and do not connect your Online Services account with accounts on third-party services.
• Promotional Activity. We collect Personal Data and Other Data from third parties who may provide promotions to you, such as sweepstakes, contests, or other offers.
• Other Sources & Service Providers. We collect Personal Data and Other Data from various third parties, such as public databases, joint marketing partners, and online travel agencies (OTAs).
• Online Services. We collect Personal or Other Data when you interact with our Online Services, by performing such actions as, but not limited to, browsing, making a reservation, purchasing goods and services from our websites or Apps, communicating with us, or otherwise connecting with us or posting to social media pages, or signing up for a newsletter or participating in a survey, contest or promotional offer.
• Customer Care Centres. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax, or contact customer service. These communications may be recorded for purposes of quality assurance and training.
• Internet-Connected Devices. We collect Personal and Other Data from internet-connected devices available on our property. For example, when you connect a device to the hotel’s internet.

Our full Privacy Policy Includes our Cookie Policy

WHY WE COLLECT YOUR DATA (LEGAL BASIS)

Our goal is to serve you better and meet your expectations and preferred level of hospitality at each stage, from the moment that you book with us through to when you check out. See below to learn more.

Our goal is to provide you with the highest level of hospitality and Services and to do so, we may share Personal Data and Other Data with the following:

• The Johnstown Estate. We disclose Personal Data and Other Data to other companies within The Johnstown Estate for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs, and accomplishing our business purposes. We share your Personal Data and Other Data used for making reservations with the applicable property and The Johnstown Estate entity to fulfill and complete your reservation.
• Owners: We disclose Personal Data and Other Data to Owners of The Johnstown Estate branded properties for the purposes described in this Global Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Owners may use your Personal Data for complying with their own legal obligations, including maintaining books & records and other compliance obligations.
• On-Property and/or Travel Providers. We may share your information with spa, restaurant, health club, concierge, and other outlets at our properties to provide you with services and their own marketing such as The Spa.
• Promotional Activity. We partner with third parties who may provide promotions to you, such as sweepstakes, contests, or other offers.
• Service Providers. We disclose Personal Data and Other Data to third-party service providers including, for example, companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology, and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.

Other Uses and Disclosures:

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations, such as in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of The Johnstown Estate business, assets or stock (including any bankruptcy or similar proceedings); (f) to protect the rights, privacy, safety or property of The Johnstown Estate, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law.

At The Johnstown Estate, we believe that you should have choices with respect to your data. We provide you with the options, information, and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

Communications and Preferences

• If you no longer wish to receive marketing-related emails, you can also use the unsubscribe link at the bottom of any of our communications
• NOTE: Even if you choose to opt-out of marketing-related emails, we will continue to send you transactional messages, such as information about your reservations or stays, including confirmation and pre-arrival emails, or account security updates.
• If you want to adjust your Stay with us, email reservations@thejohnstownestate.com or call us at (+353) 46 954 0000

Cookies and Other Data

For information on your choices related to Cookies and Other Data, please see the Section on our Cookies Policy below.

How You Can Request to Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Data

If you would like to request to access, change, delete, restrict the use of, or object to the processing of your Personal Data that you have previously provided to us, feel free to contact us at info@thejohnstownestate.com. Please see also, marketing@thejohnstownestate.com.

For your protection, we only fulfill requests for the Personal Data associated with the email address and/or loyalty account number that you identify in your request, and we may need to verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

The Johnstown Estate acknowledges and respects our guests’ privacy and we will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

OTHER IMPORTANT PROVISIONS

Non-The Johnstown Estate Group Entities

This Privacy Statement does not address, and we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our social media pages.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.

Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)

Sensitive Data

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or another government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.

Updates to This Privacy Statement

The “Last Updated” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at info@thejohnstownestate.com.

We are committed to practicing and encouraging environmental best-practice to ensure the long-term sustainability of the tourism industry. We have been awarded a 100% Green Energy Certificate 2021, which we have continued to maintain for the past 6 years.

Major Targets & Objectives

If you have any questions about this Privacy Statement, please contact us at info@thejohnstownestate.com.

The data controller responsible for your personal data is The Johnstown Estate. with an address of:

The Johnstown Estate

Enfield,

Co. Meath,

Ireland

A83 V070

Additional Information

DATA CONTROLLER

The Johnstown Estate acts as an independent data controller, who have a limited right to use the Data we collect as described below:

You can also:

• Contact our data protection officer responsible for your country or region via info@thejohnstownestate.com. In your email, please indicate the country from which you are contacting us.

Lodge a complaint with a data protection authority for your country or region or where any alleged infringement of applicable data protection laws occurs. For the EEA, a list of the national data protection authorities can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

Last Updated: April 13, 2022