THE GREEN Holiday Let Data and Privacy Policy v1 Feb 2021

This Policy

Here at The Green we are committed to protecting and respecting your privacy and personal data. This policy will inform you as to how we collect and process your personal data through your use of our website, including any data you may provide through to us when you make a booking enquiry or place a booking with us. We will keep this policy under regular review.

It is important that you read this privacy policy or any other fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other notices, policies or terms and conditions we may have and is not intended to override them.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

In order to fulfil our contractual obligations to you (our guests or potential guests) we have to collect and keep secure certain information that identifies you, known as Personally Identifiable Information (PII). Changes to the Data Protection laws with the introduction in May 2018 of the GDPR (General Data Protection Regulations) require us to provide the information below regarding the processing of your PII:

Who we are, what we do:

We are Richard Duckworth & Carly Caveney t/a The Green and we provide holiday let accommodation in properties that we own and manage. The properties are located at The Green, Ravenstonedale, Kirkby Stephen CA17 4NW.  We determine how and why your personal data is processed, and as such we are the data controller. We are registered with the Information Commissioner’s Office (ICO)

What data do we collect:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: includes first name, last name, username or similar identifier, marital status, title, date of birth, occupation, gender and passport details if you are not a UK resident.

Contact Data: includes billing address, delivery address, email address and telephone numbers.

Financial Data: includes bank account and payment card details.

Transaction Data: includes details about payments to and from you and other details of bookings you have made with us.

Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Experience & Preferences Data: includes details of your experience in booking with us or staying at our properties, your interests, preferences, feedback and survey responses.

Usage Data: includes information about how you use our website and services.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Anonymised or Aggregated Data such as statistical or demographic data for any purpose. Anonymised or Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Anonymised or Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We use Google Analytics (GA) to help us review our marketing performance but GA is configured to anonymise IP addresses.

How is your data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you make a booking enquiry, place a booking, cancel your booking, request marketing to be sent to you or give us feedback or contact us.

Interactions with the lead person in your party. Your Identity and Contact details may be given to us by the lead person in your party (i.e. the person that placed the booking) as part of a list of the persons staying at our property.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Contact, Financial and Transaction Data may be collected from or shared with providers of technical, payment and delivery services.

How we use your personal data:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data:

There are a number of legal bases for collecting and using data that are defined by different headings under GDPR. The headings that apply to our relationship with you are Contract, Legal Obligation, Legitimate Interest, and Consent.

Booking contracts: We collect the information we need to answer any enquiry you make regarding our holiday accommodation, and to process any resulting booking from initial booking through to your departure and any subsequent communication or feedback. The basis for this is defined under GDPR as Contract.


Accounting and Tax: We use information to enable us to produce figures to meet our legal obligations for accounting and tax. The basis for this is defined under GDPR as Legal Obligation.


Market research: We analyse information to enable us to assess trends in booking patterns, and how we have obtained bookings (e.g. via a third-party listing site, direct to our website, recommendations and others) and how many enquiries convert to bookings. This helps us to make best decisions on how we use our advertising budget. The basis for this is defined under GDPR as Legitimate Interest


Direct Marketing Mailshots and Newsletters: We send occasional newsletters and special offers via email to previous guests.  For this purpose, we manage a list of names and email addresses. Your information will only be on the list if you have given your Consent to receive our mailshots and have not subsequently unsubscribed from the list. You will have the option to unsubscribe with each email we send, and at any time by means of an “Unsubscribe” button or check box on our website. Your information will not be added to our mailing list unless you give specific clear consent by way of an “Opt In” check box. The basis for this is defined under GDPR as Consent.

How we store your data:

Data is stored on a password protected third party booking management platform on their secure server. We may download part or all of the data to our own password and firewall protected PC for research, accounting and tax, and marketing purposes as described above.
Copies of emails are stored on our own password and firewall protected PC, and on the secure server of the hosting service and email provider for our website domain.

How long we keep your data:

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal and/or tax purposes.

 

In some circumstances you can ask us to delete your data: see below for further information.

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the UK Information Commissioner of a breach where we are legally required to do so.

Third-party links

Please note that our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of the external websites you are visiting.

 

Your rights to see the information we hold about you:

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

 

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy.

    • Where our use of the data is unlawful but you do not want us to erase it.

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you have any concerns please contact us by email using the following email address: hello@thegreencumbria.co.uk. We try to respond to all legitimate requests within one month.

Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data privacy issues (www.ico.org.uk) if you feel we have not protected your data properly. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.