This Privacy Policy describes how Nenwell (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what pages or products you view, search terms, and how you interact with the Site.
Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.

Order information

Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit and debit card numbers, PayPal and Apple Pay details), email address, and phone number.
Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Source of collection: collected from you.

Customer support information

Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit and debit card numbers, PayPal and Apple Pay details), email address, and phone number.
Purpose of collection: to provide customer support.
Source of collection: collected from you.

Minors

The Site is not intended for individuals under the age of 16 years. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:
We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We use Pixel to gain information on how you interact with the site. We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers. We will never sell your details to third parties.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the UK and European Economic Area (“EEA”), we process your personal information under the following lawful bases:
Your consent;
The performance of the contract between you and the Site;
Compliance with our legal obligations;
To protect your vital interests;
To perform a task carried out in the public interest;
For our legitimate interests, which do not override your fundamental rights and freedoms.
How long we keep information
We keep information for as long as necessary to comply with legislation or to fulfil the purpose for which we collected the information. Order data is kept for 7 years according to the legal requirements and this timescale will change in line with any new directives.

Your rights GDPR

If you are a resident of the UK and EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at nw@nenwell.com. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

Information

At Nenwell, we understand that your privacy is extremely important. This is why we are fully dedicated to keeping your information secure.

Nenwell only collects information that is necessary to fulfill the services requested, and does not share your information with any third party, or sell it to outside marketers.

Testimonials submitted by customers become property of Nenwell and may be used at our discretion. If your testimonial is made public, we reserve the right to list your name and general location.

Security

Our website employs industry-standard encryption technologies to provide maximum security at the time of purchase. You can rest assured knowing your credit card information is safely transmitted and processed.

User Account

Users may review and modify the information stored in their accounts at any time.

Minors

Minors under the age of 18 may browse our website, but are forbidden from purchasing products.

We do not collect information from minors.

Analytics

Nenwell collects anonymous usage statistics from users. This helps us keep track of our website and ultimately improve the customer experience. 

Cookies

Nenwell's website makes use of cookies. These are small digital files that are stored in your web browser that enable us to track certain activities on our site. Cookies can be disabled at any time, however you will not be able to complete a purchase in such a case.

Links

Nenwell may provide links to other websites that may be of interest to our users. Note that we do not control the activity of other websites, nor are we responsible for their content or security.

Changes

Nenwell may change the Privacy Policy from time to time, without notification, to better serve your needs.

Please feel free to contact us if you have any questions regarding our policy.

Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by contacting us.

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyses our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

    Session Cookies: We use Session Cookies to operate our Service.

    Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

    Security Cookies: We use Security Cookies for security purposes.

Use of Data

Nenwell uses the collected data for various purposes:

    To provide and maintain our Service

    To notify you about changes to our Service

    To allow you to participate in interactive features of our Service when you choose to do so

    To provide customer support

    To gather analysis or valuable information so that we can improve our Service

    To monitor the usage of our Service

    To detect, prevent and address technical issues

    To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Nenwell legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Nenwell may process your Personal Data because:

    We need to perform a contract with you

    You have given us permission to do so

    The processing is in our legitimate interests and it is not overridden by your rights

    To comply with the law

Carbon Reduction Projects

We have already implemented the following specific environmental management measures and projects:

● Updated our business travel policy to reduce flights and encourage more digital meetings.

● Eliminated all company vehicles to reduce driving.

● Introduced a hybrid working policy to reduce daily employee travel.

● Ensured waste recycling facilities across all offices.

● Introduced a digital by default policy which prohibits printing of documents in all but exceptional circumstances.

In the future we hope to implement further environmental measures such as:

● Repurposing and recycling of all laptops and phones

● Achieving ISO14001 certification

MODERN SLAVERY STATEMENT

This statement outlines our actions and activities regarding efforts to combat slavery and human trafficking within our business and supply chain, and is produced to comply with the Modern Slavery Act.Nenwell ( “Company”, “we”, “us”, or “our”), publicly acknowledged its commitment to operate its business in a manner consistent with the United Nations Universal Declaration of Human Rights and Global Compact since 2007 when it first published its Human Rights Policy Statement, a commitment which we continue. This is reflective of the Company’s core values, culture of ethical business practices and commitment to corporate social responsibility.

Policies

Nenwell has in place business principles to help eliminate the potential use of Company owned and managed properties for slavery and human trafficking. Nenwell’s Business Principles represent the core of our business philosophy requiring our employees to act both ethically and legally when dealing with fellow employees and third parties with whom we do business. As mentioned above, we also abide by our Human Rights Policy Statement, reflecting our commitment to protect human rights within our sphere of influence. We also expect our suppliers to act in a compliant and ethical manner, and as such, we ask our suppliers to meet the criteria established in our Supplier Code of Conduct, which, among other things, sets forth our expectations of our suppliers with respect to forced labor and child hiring practices. Although we do not own or operate franchised hotels, our franchisees agree to comply with all laws that apply to their hotels, which includes all anti-trafficking laws.

Training

The Company requires employees to attend training on its Business Principles. Compliance with this training requirement is monitored. In addition, Nenwell has introduced training to our employees relating to slavery and human trafficking. Moreover, our new hire orientation includes education about Corporate Social Responsibility and our Human Rights program. In addition, we make a reasonable effort to positively influence parties over which we do not have operational control. In that respect, we make available training and education about child labor and human trafficking to our independently owned and controlled franchisees through webinars, seminars at our global hotel conferences and online portals, and provide educational materials to our approved suppliers on slavery and human trafficking.

Risk Management

Nenwell also has in place processes to help eliminate the potential use of the Company’s owned and managed properties for slavery and human trafficking. All our employees can consult with experts who will help them identify suspected signs of slavery and human trafficking and report such matters to the authorities. Moreover, globally, we distribute information which assists employees with identifying potential signs of slavery and human trafficking and provides a process for timely escalating concerns within the organization.

Supply Chain

We have focused our anti-human trafficking efforts within our own operations and by reviewing certain suppliers that participate in our approved supplier program, Our supply chain covers procurement at the corporate and local levels. The Company has an approved supplier program that supports the purchasing efforts of our owned and managed properties, as well as independently owned and controlled franchisees, by negotiating prices and volume discounts for products and services with third-party suppliers. We take a risk-based approach to performing due diligence. To the extent a supplier did not meet our due diligence requirements or our standards for ethical conduct as outlined in our Supplier Code of Conduct, we do not approve the supplier and, as to previously approved suppliers, require corrective action and terminate if necessary. We have developed a risk-based approach to report, manage and roll out programs intended to combat slavery and human trafficking in areas where we believe there is a high risk of such activity and where we have operational control over the business and our supply chain. We will continue to monitor, refine and implement programs, previously used by Nenwell. Through these programs we are able to measure number of personnel trained as well as number of suppliers evaluated.