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Draft — pending review by our solicitors. This document is a working draft, is not yet final, and does not yet constitute a legal agreement. Items shown in [square brackets] are placeholders that will be completed before the platform goes live.

Privacy Policy

Last updated: 4 August 2026 · Draft for review

This Privacy Policy explains how [PLACEHOLDER: registered company name] Ltd (“BushidoPay”, “we”, “us”) collects and uses personal data when you use our website or contact us. We are the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

[PLACEHOLDER: registered company name] Ltd is a company registered in England & Wales (company number [PLACEHOLDER: company number]), with its registered office at [PLACEHOLDER: registered office address]. We are registered with the Information Commissioner’s Office (ICO) under reference [PLACEHOLDER: ICO registration number].

2. The data we collect

We collect the personal data you provide directly through our forms:

  • Hotel registration (Join): hotel name, city, country, number of rooms, contact name and role, email address, phone number, areas of interest and any notes you add.
  • Enquiries (Contact): your name, role, organisation, email address, phone number, country, enquiry type and message.

We do not collect special category data, and we do not knowingly collect data from children. Our forms include a hidden anti-spam field that is not used to profile you.

3. How we use your data and our lawful basis

  • To respond to your enquiry and progress your registration — our lawful basis is your consent, and our legitimate interest in responding to business enquiries.
  • To provide and administer the BushidoPay programme where you become a participant — our lawful basis is performance of a contract.
  • To meet legal and regulatory obligations — our lawful basis is legal obligation.

4. Sharing your data

We do not sell your personal data. We share it only with service providers who help us operate the platform (for example our hosting and email providers), and with campaign partners such as i-media where necessary to deliver a service you have requested. All such providers are bound by appropriate data-processing terms.

5. Retention

We keep enquiry and registration data only for as long as necessary to respond to you and to administer any resulting relationship, and thereafter for [PLACEHOLDER: retention period] in line with our legal obligations, after which it is securely deleted.

6. Your rights

Under UK GDPR you have the right to:

  • access the personal data we hold about you;
  • request correction of inaccurate data;
  • request erasure of your data;
  • restrict or object to our processing;
  • data portability; and
  • withdraw consent at any time.

To exercise any of these rights, contact us at [PLACEHOLDER: privacy/DPO email address].

7. Cookies

We use only strictly necessary cookies. See our Cookie Policy for details.

8. Complaints

If you have a concern about how we handle your data, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

9. Contact

Questions about this policy or your data can be sent to [PLACEHOLDER: privacy/DPO email address], or by post to the registered office above.