Privacy Notice
This is the privacy notice of The Little Holiday Co St Ives.
Our registered office is at 25 Marden Way, Calne SN11 0RX
Introduction
This notice describes how we collect, store, transfer and use personal data. It tells
you about your privacy rights and how the law protects you.
In the context of the law and this notice, ‘personal data’ is information that clearly
identifies you as an individual or which could be used to identify you if combined with
other information. Acting in any way on personal data is referred to as ‘processing’.
This notice applies to personal data collected through our website and through social
media platforms and online retail platforms, including [ e.g.
Facebook, Instagram, Twitter].
we do not share, or sell, or disclose to a third party, any information collected through our website.
Data Protection Officer
We have appointed a data protection officer (‘DPO’) who is responsible for ensuring
that our privacy policy is followed.
If you have any questions about how we process your personal data, including any
requests to exercise your legal rights, please contact our DPO, Becky Nicholls by emailing thelittleholidaycostives@gmail.com
Personal data we process
1. How we obtain personal data
The information we process about you includes information:
you have directly provided to us
3 © Andrew Taylor and Net Lawman Ltd
that we gather from third party databases and service providers
as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly
When you use our website, our services or buy from us, [for example, when
you create an account on our website,] we ask you to provide personal data.
This can be categorised into the following groups:
personal identifiers, such as your first and last names, your title and
your date of birth
contact information, such as your email address, your telephone
number and your postal addresses for billing, delivery and
communication
account information, including your username and password
payment information, such as a debit or credit card number and expiry
date and bank account details
records of communication between us including messages sent
through our website, email messages and telephone conversations
marketing preferences that tell us what types of marketing you would
like to receive
In addition, we may also process:
documentation that confirms your identity, such as an image of your
passport or driver’s licence
an image that shows your face, such as a passport photograph
documentation that confirms the qualifications you advertise as holding
documentation that confirms your employment, such as recent payslips
documentation that confirms your address, such as a tenancy
agreement or rental contract
3. Types of personal data we collect from third parties
We confirm some of the information you provide to us directly using data from
other sources. We also add to the information we hold about you, sometimes
to remove the need for you to provide it to us and sometimes in order to be
able to assess the quality of the services you offer.
The additional information we collect can be categorised as follows:
information that confirms your identity
business information, including your business trading name and
address, your company number (if incorporated), and your VAT
number (if registered)
information that confirms your contact information
reviews and feedback about your business on other websites through
which you sell your services
unsolicited complaints by other users
4. Types of personal data we collect from your use of
our services
By using our website and our services, we process:
your username and password and other information used to access our
website and our services
information you contribute to our community, including reviews
your replies to polls and surveys
technical information about the hardware and the software you use to
access our website and use our services, including your Internet
Protocol (IP) address, your browser type and version and your device’s
operating system
usage information, including the frequency you use our services, the
pages of our website that you visit, whether you receive messages
from us and whether you reply to those messages
transaction information that includes the details of the products
services you have bought from us and payments made to us for those
services
your preferences to receive marketing from us; how you wish to
communicate with us; and responses and actions in relation to your
use of our services.
5. Our use of aggregated information
We may aggregate anonymous information such as statistical or demographic
data for any purpose. Anonymous information is that which does not identify
you as an individual. Aggregated information may be derived from your
personal data but is not considered as such in law because it does not reveal
your identity.
For example, we may aggregate usage information to assess whether a
feature of our website is useful.
However, if we combine or connect aggregated information with your personal
data so that it can identify you in any way, we treat the combined information
as personal data, and it will be used in accordance with this privacy notice.
6. Special personal data
We may collect special personal data about you if there is a lawful basis on
which to do so.
7. If you do not provide personal data we need
Where we need to collect personal data by law, or under the terms of a
contract we have with you, and you fail to provide that data when requested,
we may not be able to perform that contract.
In that case, we may have to stop providing a service to you. If so, we will
notify you of this at the time.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process
different categories of your personal data, and to notify you of the basis for each
category.
If a basis on which we process your personal data is no longer relevant then we shall
immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of
any new basis under which we have determined that we can continue to process
your information.
8. Information we process because we have a
contractual obligation with you
When you create an account on our website, buy a product or service from
us, or otherwise agree to our terms and conditions, a contract is formed
between you and us.
In order to carry out our obligations under that contract we must process the
information you give us. Some of this information may be personal data.
We may use it in order to:
verify your identity for security purposes when you use our services
sell products to you
provide you with our services
provide you with suggestions and advice on products, services and
how to obtain the most from using our website
We process this information on the basis there is a contract between us, or
that you have requested we use the information before we enter into a legal
contract.
We shall continue to process this information until the contract between us
ends or is terminated by either party under the terms of the contract.
9. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship
between us, such as when you browse our website or ask us to provide you
more information about our business, including [job opportunities and] our
products and services, you provide your consent to us to process information
that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this
information, for example, we ask you to agree to our use of non-essential
cookies when you access our website.
If you have given us explicit permission to do so, we may from time to time
pass your name and contact information to selected associates whom we
consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your
consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us [at email
address or webpage]. However, if you do so, you may not be able to use our
website or our services further.
We aim to obtain and keep your consent to process your information.
However, while we take your consent into account in decisions about whether
or not to process your personal data, the withdrawal of your consent does not
necessarily prevent us from continuing to process it. The law may allow us to
continue to process your personal data, provided that there is another basis
on which we may do so. For example, we may have a legal obligation to do
so.
10. Information we process for the purposes of legitimate
interests
We may process information on the basis there is a legitimate interest, either
to you or to us, of doing so.
Where we process your information on this basis, we do after having given
careful consideration to:
whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you
would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
improving our services
record-keeping for the proper and necessary administration of our
business
responding to unsolicited communication from you to which we believe
you would expect a response
preventing fraudulent use of our services
exercising our legal rights, including to detect and prevent fraud and to
protect our intellectual property
insuring against or obtaining professional advice that is required to
manage [organisational or business] risk
protecting your interests where we believe we have a duty to do so
11. Information we process because we have a legal
obligation
Sometimes, we must process your information in order to comply with a
statutory obligation.
For example, we may be required to give information to legal authorities if
they so request or if they have the proper authorisation such as a search
warrant or court order.
This may include your personal data.
12. Information we process to protect vital interests
In situations where processing personal information is necessary to protect
someone’s life, where consent is unable to be given and where other lawful
bases are not appropriate, we may process personal information on the basis
of vital interests.
For example, we may inform relevant organisations if we have a safeguarding
concern about a vulnerable person.
How and when we process your personal data
13. Your personal data is not shared
We do not share or disclose to a third party, any information collected through
our website.
14. Information you provide
Our website allows you to post information with a view to that information
being read, copied, downloaded, or used by other people.
For example, when you leave a review or post a message on our website, we
reasonably assume that you consent for the message to be seen by others.
We may include your username with your message, and your message may
contain information that is personal data.
Other examples include:
tagging an image
clicking on an icon next to another visitor’s message to convey your
agreement, disagreement or thanks
In posting personal data, it is up to you to satisfy yourself about the privacy
level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or
shared.
We do store it, and we reserve a right to use it in the future in any way we
decide.
We provide you with a public profile page, the information on which may be
indexed by search engines or used by third parties. The information you
provide on that profile page may be made available to the public.
Once your information enters the public domain, we have no control over what
any individual third party may do with it. We accept no responsibility for their
actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain
it, then at our discretion we may agree to your request to delete personal data
that you have posted. You can make a request by contacting us at [email
address or webpage].
15. Payment information
Payment information is never taken by us or transferred to us either through
our website or otherwise. Our employees and contractors never have access
to it.
At the point of payment, you are transferred to a secure page on the website
of WorldPay PayPal / Stripe or some other
reputable payment service provider. That page may be branded to look like a
page on our website, but it is not controlled by us.
18. Information obtained from third parties
Although we do not disclose your personal data to any third party (except as
set out in this notice), we sometimes receive data that is indirectly made up
from your personal data from third parties whose services we use.
No such information is personally identifiable to you.
19. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their
agents or other companies working for them may use technology that
automatically collects information about you when their advertisement is
displayed on our website.
They may also use other technology such as cookies or JavaScript to
personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties
obtain. Accordingly, this privacy notice does not cover the information
practices of these third parties.
20. Credit reference
To assist in combating fraud, we share information with credit reference
agencies, so far as it relates to clients or customers who instruct their credit
card issuer to cancel payment to us without having first provided an
acceptable reason to us and given us the opportunity to refund their money.
21. Disputes between users
In the event of a dispute between you and another user, provided that you
consent, we may share your basic personal data, business information and
contact information with the other user.
At our discretion, we may share other information to enable the dispute to be
resolved through litigation or alternative dispute resolution methods.
22. Service providers and business partners
We may share your personal data with businesses that provide services to us,
or with business partners.
As examples:
we may pass your payment information to our payment service
provider to take payments from you
we may use fraud prevention agencies and credit reference agencies
to verify your identity and we may pass your information to those
agencies if we strongly suspect fraud on our website
we may pass your contact information to advertising agencies to use to
promote our services to you
23. Referral partners
This is information given to us by you in your capacity as an affiliate of us or
as a referral partner.
It allows us to recognise visitors that you have referred to us, and to credit to
you commission due for such referrals. It also includes information that allows
us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the
terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems
24. Cookies
Cookies are small text files that are placed on your computer's hard drive by
your web browser when you visit a website that uses them. They allow
information gathered on one web page to be stored until it is needed for use
at a later date.
They are commonly used to provide you with a personalised experience while
you browse a website, for example, allowing your preferences to be
remembered.
They can also provide core functionality such as security, network
management, and accessibility; record how you interact with the website so
that the owner can understand how to improve the experience of other
visitors; and serve you advertisements that are relevant to your browsing
history.
Some cookies may last for a defined period of time, such as one visit (known
as a session), one day or until you close your browser. Others last indefinitely
until you delete them.
Your web browser should allow you to delete any cookie you choose. It
should also allow you to prevent or limit their use. Your web browser may
support a plug-in or add-on that helps you manage which cookies you wish to
allow to operate.
The law requires you to give explicit consent for use of any cookies that are
not strictly necessary for the operation of a website.
When you first visit our website, we ask you whether you wish us to use
cookies. If you choose not to accept them, we shall not use them for your visit
except to record that you have not consented to their use for any other
purpose.
If you choose not to use cookies or you prevent their use through your
browser settings, you may not be able to use all the functionality of our
website.
We use cookies in the following ways:
to track how you use our website
to record whether you have seen specific messages we display on our
website
to keep you signed in to our website
to record your answers to surveys and questionnaires on our site while
you complete them
to record the conversation thread during a live chat with our support
team
[We provide more information about the cookies we use in our cookie policy].
25. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other
content on our website are recorded.
We record information such as your geographical location, your Internet
service provider and your IP address. We also record information about the
software you are using to browse our website, such as the type of computer
or device and the screen resolution.
We use this information in aggregate to assess the popularity of the
webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits,
the data possibly could be used to identify you personally, even if you are not
signed in to our website.
26. Re-marketing
Re-marketing involves placing a ‘tracking technology’ such as a cookie, a
‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track
which pages you visit and to serve you relevant adverts for our services when
you visit some other website.
The benefit of re-marketing technology is that we can provide you with more
useful and relevant adverts, and not show you ones repeatedly that you may
have already seen.
We may use a third-party advertising service to provide us with re-marketing
services from time to time. If you have consented to our use of such tracking
technologies, you may see advertisements for our products and services on
other websites.
We do not provide your personal data to advertisers or to third-party re-
marketing service providers. However, if you are already a member of a
website whose affiliated business provides such services, that affiliated
business may learn of your preferences in relation to your use of our website.
Other matters
27. Your rights
The law requires us to tell you about your rights and our obligations to you in
regard to the processing and control of your personal data.
We do this now, by requesting that you read the information provided at
http://www.knowyourprivacyrights.org
28. Use of our services by children
We do not sell products or provide services for purchase by children, nor do
we market to children.
If you are under 18, you may use our website only with consent from a parent
or guardian.
We collect data about all users of and visitors to these areas regardless of
age, and we anticipate that some of those users and visitors will be children.
29. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your
browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done
so using SSL by looking for a closed padlock symbol or other trust mark in
your browser’s URL bar or toolbar.
30. Delivery of services using third party communication
software
With your consent, we may communicate using software provided by a third
party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or
Zoom Video Communications (Zoom).
Such methods of communication should secure your personal data using
encryption and other technologies. The providers of such software should
comply with all applicable privacy laws, rules, and regulations, including the
GDPR.
If you have any concerns about using a particular software for communication,
please tell us.
31. Data may be processed outside the UK
Our websites are hosted in the UK
We may also use outsourced services in countries outside the UK from time
to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be
processed outside the UK.
We use the following safeguards with respect to data transferred outside the
UK:
the processor is within the same corporate group as our business or
organisation and abides by the same binding corporate rules regarding
data processing.
the data protection clauses in our contracts with data processors
include transfer clauses written by or approved by a supervisory
authority.
we comply with a code of conduct approved by a supervisory authority.
we are certified under an approved certification mechanism as
provided for in the Act.
both our organisation and the processor are public authorities between
whom there is either a legally binding agreement or administrative
arrangements approved by a supervisory authority relating to
protection of your information.
1. Control over your own information
It is important that the personal data we hold about you is accurate and up to
date. Please inform us if your personal data changes.
At any time, you may contact us to request that we provide you with the
personal data we hold about you.
At any time you may review or update personally identifiable information that
we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you
should contact us to make that request.
When we receive any request to access, edit or delete personal data we first
take reasonable steps to verify your identity before granting you access or
otherwise taking any action. This is important to safeguard your information.
Please be aware that we are not obliged by law to provide you with all
personal data we hold about you, and that if we do provide you with
information, the law allows us to charge for such provision if doing so incurs
costs for us. After receiving your request, we will tell you when we expect to
provide you with the information, and whether we require any fee for providing
it to you.
If you wish us to remove personally identifiable information from our website,
you should contact us to make your request.
This may limit the service we can provide to you.
We remind you that we are not obliged by law to delete your personal data or
to stop processing it simply because you do not consent to us doing so. While
having your consent is an important consideration as to whether to process it,
if there is another legitimate basis on which we may process it, we may do so
on that basis.
2. Communicating with us
We may keep personally identifiable information associated with your
message, such as your name and email address so as to be able to track our
communications with you to provide a high quality service.
3. Complaining
If you are not happy with our privacy policy, or if you have any complaint, then
you should tell us.
When we receive a complaint, we record the information you have given to us
on the basis of consent. We use that information to resolve your complaint.
We aim to investigate all complaints relating to user generated content.
However, we may not be able to do so as soon as a complaint is made. If we
feel that it is justified or if we believe that the law requires us to do so, we shall
remove the content while do so.
Making a complaint may not result in the removal of the content. Ultimately,
we have to make a judgment as to whose right will be obstructed: yours, or
that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not
correspond with you about it.
If your complaint reasonably requires us to notify some other person, we may
decide to give to that other person some of the information contained in your
complaint. We do this as infrequently as possible, but it is a matter for our sole
discretion whether we do give information, and if we do, what that information
is.
We may also compile statistics showing information obtained from this source
to assess the level of service we provide, but not in a way that could identify
you or any other person.
If a dispute is not settled then we hope you will agree to attempt to resolve it
by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal data,
you have a right to lodge a complaint with the Information Commissioner's
Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We
would, however, appreciate the opportunity to talk to you about your concern
before you approach the ICO.
4. Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal
data only for as long as required by us:
to provide you with the services you have requested
to comply with other law, including for the period demanded by our tax
authorities
to support a claim or defence in court
5. Compliance with the law
Our privacy policy complies with the law in the United Kingdom, specifically
with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU
General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic
Communications Regulations (‘PECR’).
6. Review of this privacy policy
We shall update this privacy notice from time to time as necessary.
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