Elite Hotels (Rotherwick) Ltd and it’s subsidiary companies, Ashdown Park (Sussex) Ltd, The Grand Hotel (Eastbourne) Ltd, Luton Hoo Park Ltd and Tylney Hall Hotel Ltd is committed to meeting its obligations under the General Data Protection Regulations ‘GDPR’ and ensuring the privacy and security of all personal information.

This Privacy Policy explains what personal information the company collects and how it handles this information, to ensure that an individual’s rights are protected.

Personal Information

What information do we collect?

When you make an enquiry or reservation with our hotels, we may ask you to provide certain personal information including your full name, email address, home address, contact number and payment details.

When you visit our websites we may also collect information on an ongoing basis through on-line analytics tools about what pages you access or visit, and information about your use of our site, for example the pages viewed, the website from which you came to visit our site, changes you make to information you provided to us and your transactions including by use of cookies.

What legal basis do we rely on when collecting and processing personal data?

Performance of a contract: The use of your information may be necessary to perform the contract that you have with us. For example, if you use our services to make an online reservation, we will use your information to carry out our obligation to complete and administer that reservation under the contract that we have with you.

Legitimate interests: We may use your information for our legitimate interests, such as provide you with the best suitable content of the website, emails and newsletters, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes.

Consent: We may rely on your consent to use your personal information for certain direct marketing purposes. You may withdraw your consent at any time by contacting us at the addresses at the end of this Privacy Statement

What do we use your information for?

  • We may use your information for the following purposes:
  • in the normal course of our business, to allow us to register you to use our hotels and services and to provide you with our services on the basis that processing is necessary in order to perform our contract with you to provide our services;
  • to allow us to manage your reservation on the basis that processing is necessary in order to perform our contract with you to provide our services;
  • to allow us to analyse your personal preferences and personalise our services to you;
  • to store your data to pre-populate fields to make it easier for you to provide information when you return to our sites;
  • to communicate with you including sending you information about products and services which we think may be of interest to you. You will be able to opt-out of such communications at any time by clicking on the unsubscribe link.
  • to validate your information to check that the data we hold about our customers is accurate, consistent and up to date on the basis that processing is necessary in order to perform our contract with you to provide our services;
  • in pursuit of our legitimate interests, to record CCTV footage to ensure the safety and security of our premises, staff and customers;
  • to comply with any legal obligations to which we are subject

We shall periodically check that the personal data we store for you is accurate

Who do we share your information with?

The information and data we collect is important for us and we would not want to share this with anyone else. Unless we have your express consent, we will never disclose, rent, trade or sell your personal data to any third parties for their marketing or mailing purposes. The only exception to this is Luton Hoo Park Ltd who currently shares data with Vision Marketing Ltd, trading as Luxury Restaurant Guide who acts as the data processor of Elite Privileges memberships. For information on how Vision Marketing Limited/ Luxury Restaurant Guide protects your data and your rights, and how to exercise them, please see their Privacy Policy at https://www.luxuryrestaurantguide.com/PrivacyPolicy

We do disclose or transfer your data or personal information to other companies, data processors or agents employed by us to perform any necessary functions on our behalf, for example the processing of direct debit payments, but they are bound by our privacy policy and may not use this information for their own purposes.

How long do we store your personal data for?

We only store your personal information for as long as necessary for the purposes listed under the ‘What do we use your information for?’ section and to meet our legal obligations as a company.  

What are your rights?

Access to your personal data: You have the right to request a copy of any information which we hold about you. If you wish to receive a copy of this information please contact Elite Hotels (Rotherwick) Ltd, Ashdown Park, Wych Cross, Forest Row, East Sussex RH18 5JR

Right to withdraw: Where you have given your consent for us to use your personal data, you may withdraw your consent at any time.

Rectification: You may ask us to rectify inaccurate information held about you. If you would like to update the data we hold about you, please contact Elite Hotels (Rotherwick) Ltd, Ashdown Park, Wych Cross, Forest Row, East Sussex RH18 5JR with your request

Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us on the contact details above, specifying why you would like us to delete your personal data.

Portability: You may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller.

Right to object: You may object to our processing of your personal data pursuant to this Privacy Policy. Please contact us on the contact details above, providing details of your objection.

Cookies policy

Cookies are small files saved to your computer’s hard drive that track, save and store information as well as your interactions and usage of our websites. The primary purpose for collection of data from users to our site is to allow us to provide a smooth efficient and personalised experience while using our site. Where applicable the website(s) uses a cookie control system allowing you on your first visit to the website(s) to allow or disallow the use of cookies on your computer/device.

You are advised that if you do not consent to the use and saving of cookies from the website(s) on to your computer hard drive then you should take necessary steps within your web browser security settings to block all cookies from this website and its external serving vendors.

Our website uses cookies software provided by Google Analytics to monitor visitor usage to better understand how the website is used. The software will save a cookie to your computer hard drive in order to track and monitor your engagement and usage of our website, but will not store, save or collect personal information.

Other cookies may be stored on your computer hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. It should be noted that no personal information is stored, saved or collected.

Security and Data Storage

We will treat all of your information in strict confidence and we will endeavour to take all reasonable steps to keep your personal information secure once it has been transferred to our systems.  We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, and data stored on our IT systems, the website(s) and associated databases.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time, so please review it regularly.

If we change this Privacy Policy we shall notify you by means of notice on our site homepage.


If you have any queries relating to this Privacy Policy or our use of your personal data, please contact. Elite Hotels (Rotherwick) Ltd, Ashdown Park, Wych Cross, Forest Row, East Sussex RH18 5JR

Gender Pay Gap Report


Luton Hoo Park Limited trading as Luton Hoo Hotel Golf and Spa is publishing its Gender Pay Gap information for the second time to the snapshot date of 5th April 2018. This report adds narrative to the hotel’s published statistics and confirms our commitment to narrowing our pay gap.

Our People

Luton Hoo Hotel aims to recruit, retain and develop the best talent to ensure we deliver distinctly memorable experiences. The company recognises its people are its greatest asset and are paramount to its long term success.

The hotel is an equal opportunities employer and is committed to the principles laid out in the Equality Act 2010. A commitment to equal opportunities in the workplace is not only good management practice; it also makes sound business sense. We wish to encourage a working environment which is free of discrimination of any kind, not only by gender.

We aim to ensure that our staff achieve their full potential and that all employment decisions are taken without reference to irrelevant or discriminatory criteria. We have adopted an equal opportunities policy as a means of helping to achieve these aims.

Remuneration Policy

The company has a consistent approach to remuneration ensuring employees are paid fairly based on company performance and market conditions. We are confident that all our HR practices and processes ensure employees are not paid differently due to gender.

Our Workforce

Based on the data as set out by the pay gap legislation, on 5th April 2018, 54.5% of employees were female. Female employees are well represented at the upper mid level and lower levels however represent a slightly smaller proportion at executive level. On average male staff remain in our employment longer. These two factors have had a significant impact on our mean and mean bonus pay gap.

Actions to close the Gap

  • Investigate ways we can further train, develop and support more females to progress into senior roles. Continue to support and further promote flexible working patterns.
  • Consider recruitment strategies to help encourage more females into our business at executive management level.
  • Develop a long term strategy to improve the balance between the number of male and female employees across all levels of the business.

Results compared with 2017/18

Our results for 2018/19 have improved. Both the mean pay gap and mean bonus pay gap have reduced. The median bonus pay gap has now swung in favour of females. That said we recognise we must continue to close the gap and are fully committed to doing so.

Our Results

The data illustrates our mean and median hourly gender pay gap is ahead of most employers compared against the national averages (17.1% mean and 17.9% median as reported by the office of national statistics).

Our mean and median bonus pay gaps have both improved (2017/18 results were 66% and 27% respectively) but the mean bonus average still shows a larger variance. This is due to several factors including on average retaining males with more than one year’s service for longer and having a smaller proportion of females in senior management roles. Overall the percentage of females employed has fallen from 56% to 54.5%, while positively, the number employed in the upper quartile has risen from 45.4% to 47.9%.

The results have been prepared by Elite Hotels on behalf of Luton Hoo Park Limited. All calculations are in line with the Equalities Act 2010 (Gender Pay Gap Information Regulations 2017). Data as at 5th April 2018.

Luton Hoo Park Limited gender pay gap:

  • Mean pay gap 8.0%
  • Median pay gap 0.0%
  • Mean bonus gap 52.6%
  • Median bonus gap -34.9%

Percentages receiving a bonus:

  • Women 19.1%
  • Men 25.1%

Conclusion and closing remarks

Luton Hoo is a committed employer that strongly believes in equality and that its people are its biggest asset. Whilst the hotel has demonstrated both improvement and that it is ahead of national averages, we continue to be committed to further closing the gap and have identified several action points to help achieve this.