Privacy Policy

McLaren International Pty Ltd (Known as: McLaren) understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Sites. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Sites. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.

McLaren International Pty Ltd operates the Sites which provide services to:

owners, managers, and staff of Hotels (“Hotels”) and event venues (“Venues”) who subscribe to the Sites (“ A Users”), and
members of the public (“B Users”).

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Sites;
“Cookie”	means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 12, below;]
“Our Sites”	means this website, mclarenint.com, and any web portals provided to our hospitality clients and their guests under the fluide brand
“We/Us/Our”	means McLaren International Pty Ltd. a private limited company registered in Australia and Singapore. <details>

2. Information About Us

2.1 Our Sites, are owned & operated by McLaren International Pty Ltd. a private limited company registered in Australia and Singapore <details>

2.2 Our Data Protection Officer is Matthew White, dpo@mclarenint.com

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. It does not extend to any websites that are linked to from Our Sites (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Sites. For further details, please see section 12 on Our use of Cookies [mclarenint.com/cookie-policy/], other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Sites, We may collect some or all of the following data:

4.1 Name;

4.2 gender;

4.3 business/company name

4.4 occupation;

4.5 contact information such as email addresses and telephone numbers;

4.6 demographic information such as City & Country;

4.7 details of your stay such as date of departure, room number;

4.8 hotel loyalty status;

4.9 IP address (automatically collected);

4.10 web browser type and version (automatically collected);

4.11 operating system (automatically collected);

4.12 a list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to (automatically collected);

5. How Do We Use Your Data?

5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2 We do not use personal data of our B Users for any purpose other than to provide services that our A Users have contracted us to provide through Our Sites, or as required by law, This includes:

5.2.1 To deliver the Sites that our A Users have contracted us to provide.

5.2.2 Providing and managing your Account;

5.2.3 Providing and managing your access to Our Sites;

5.2.4 Personalising and tailoring your experience on Our Sites;

5.2.5 Supplying Our services to you;

5.2.6 Personalising and tailoring Our services for you;

5.2.7 Responding to communications from you;

5.2.8 Supplying you with email [e.g. system notifications and alerts etc.] that you have subscribed to (you may unsubscribe or opt-out at any time) ;

5.2.9 Market research;

5.2.10 Analysing your use of Our Sites [and gathering feedback] to enable Us to continually improve Our Sites and your user experience;

5.2.11 To disclose to contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain and support Our Sites, such as, for example, payment processors and data center or Web hosting providers. We do not share, sell or trade any information with such third parties for promotional purposes.

5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, phone, messaging service, or post with information, news and offers on Our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

you have given consent to the processing of your personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which we are subject;
processing is necessary to protect the vital interests of you or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

Type of data	Type of data subject	Type of processing	Purpose of processing	Type of recipient to whom personal data is transferred	Retention period
B Users	Personal data	Electronic	Necessary for providing services as intended	IT	90 days after the termination of the A Users contract.
A Users	Personal data and lessons records	Electronic	Necessary for providing services as intended	IT, Sales, Marketing	5 years
Employees	Personal data	Electronic	Country policy	HR	7 years
Sensitive data	Financial information and unique identifiers	Electronic	Online payment system	IT	90 days after the termination of the customer contract.

6.2 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.

6.3 These are the measures we take when working with personal data:

Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely using the DoD 3 pass overwrite standard (DoD 5220.22-M) where possible.
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient;
No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from privacy@mclarenint.com.
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the Data Privacy Officer dpo@mclarenint.com;
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Data Privacy Officer dpo@mclarenint.com and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
All personal data stored electronically should be backed up Daily. All backups should be encrypted.
All electronic copies of personal data should be stored securely using passwords and data encryption;
All passwords used to protect personal data should comply with the Company’s Password Policy;

All user-level & system-level passwords should not be easy guessed and must conform to the guidelines described below: –

Passwords must be at least 8 characters long.

Passwords must contain all 3 of the 3 following character groups

A to Z

a to z

0 to 9

n. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

o. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of our Data Privacy Officer dpo@mclarenint.com to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked at least annually.

6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do We Share Your Data?

7.1 We may contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:

Service	Description and Features
Google Compute Engine (GCE)	GCE is a secure cloud services platform, offering compute power, database storage, content delivery and other functionality.
Google API	Google APIs are used for Google Maps loading and geocoding services.
Google Analytics	Google analytics is used for tracking and reporting web traffic for end-users.
Mailchimp	Mailchimp may be used for mailing list management and marketing emails.
Stripe	Stripe API services are used to process and securely store credit card transactions. Stripe as a company has been audited by an independent PCI Qualified Security Assessor (QSA) and is certified as a PCI Level 1 Service Provider. This is the most stringent level of certification available in the payments industry.
Intercom	Intercom live chat is used for customer support, on-boarding & messaging.
Facebook API	Facebook APIs are used to allow B users to log in to some of our systems with their Facebook account.
BitBucket	Bitbucket is used to store our codebase.
Salesforce	Salesforce is used for Customer Relationship Management.

7.2 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

8.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

9. How Can You Control Your Data?

9.1 When you submit information via Our Sites, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1 You may access Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.

10.2 You may restrict your internet browser’s use of Cookies. For more information, see section 12. mclarenint.com/cookie-policy/

10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at privacy@mclarenint.com or using the contact details below in section 14.

12. Cookies

11.1 Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our services. By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Sites for providing chat & communication features. In addition, Our Sites uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. For more details, please refer to Our Cookie Policy mclarenint.com/cookie-policy/

13. Summary of Your Rights under GDPR

Under the GDPR, you have:

13.1 the right to request access to, deletion of or correction of, your personal data held by Us;

13.2 the right to complain to a supervisory authority;

13.3 be informed of what data processing is taking place;

13.4 the right to restrict processing;

13.5 the right to data portability;

13.6 object to processing of your personal data;

13.7 rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Sites or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Automated Decision-Making and Profiling

14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

14.2 The right described in section 14.1 does not apply in the following circumstances:

a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;

b) The decision is authorised by law; or

c) You have given you explicit consent.

14.3 Where We use your personal data for profiling purposes, the following shall apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;

b) Appropriate mathematical or statistical procedures will be used;

c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

14.4 We currently make the following automated decisions:

a) When you visit this site or use one of our applications, we collect certain information by automated means, using technologies such as cookies, web server logs and web beacons. Information may include (i) technical information, such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone settings, language settings, domain, operating system, platform or other system settings, and (ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site, pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page and any conversations taken place over our chat application.

14.5 We currently profile your personal data for the following purposes:

a) We may use the information collected through automated means on this site to deliver personalised content for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the site, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms and Conditions. We may also use the information in other ways for which specific notice is provided at the time of collection.

15. Contacting Us

If you have any questions about Our Sites or this Privacy Policy, please contact Us by email at privacy@mclarenint.com or via our Personal Data Request form mclarenint.com/data-access-request/ . Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

16. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.