theholidaylet.com, theholidaylet ("we and us") is committed to protecting and respecting your privacy.
This Policy (together with our Terms and Conditions Policy) sets out the grounds on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand how we will treat your Personal Data.
For the purpose of the General Data Protection Regulation ("GDPR"), the data controller is theholidaylet.com. Our registered address is 9 Cadbury Road, Moseley, Birmingham, West Midlands, B13 9BH. We are registered with the Information Commissioner's Office, registration number: ZA389112
We will comply with the GDPR. The GDPR states that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Information we collect from you
When registering, we will collect your user login information and email address.
When becoming an advertiser, we will collect further contact details from you, including your name, title (Mr, Mrs, etc.), address and telephone number(s).
When completing an advert, we will also collect your advertised property details, including its address and names of any contact person or managing agent.
The legal basis for this processing is consent, namely providing you with the website services you have requested; those services being your user website registration / advertiser registration, advert and any orders placed via the website. To help prevent fraud, we may also require other personal information when you place an advert in order that we can verify your identity as well as the property you wish to advertise.
When making a property enquiry:
- We will collect your name, email address, telephone number, IP address and a copy of the enquiry contents. The legal basis for this processing is consent in so much as the enquiry must be processed by our system and forwarded to the advertiser.
- We may also send occasional marketing emails to you, with details of other holiday properties that you may be interested in. The legal basis for this processing is our legitimate interest.
If you contact us, we may keep a record of that correspondence for the purposes of communicating with you and for our record-keeping.The legal basis for this processing is our legitimate interests; to be able to contact you to help you to register or to advertise a holiday property or to answer a question related to our website advertising service.
Other information to help us provide you with improved services.The legal basis for this processing is our legitimate interests, namely our interest in the proper administration of our website, business and accounting procedures and improving the services we provide to you.
How we use your information
We use information held about you in the following ways:
- To help us identify you and the accounts you hold with us.
- To provide you with customer care.
- To enable us to develop and improve our services and website.
- To carry out our obligations arising from any registration or advertising service provided to you and to provide you with the information, products and services that you request from us.
- To carry out marketing and statistical analysis.
- To notify you about changes to our service.
- To provide you with information about advertising services or holiday properties that are similar to those that you have previously purchased or enquired about:
As an Advertiser; We will only contact you about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
As a Holidaymaker; We will only contact you as a result of a previous enquiry made by you for an advertised property. You can choose not to receive further communications via the unsubscribe facility on each contact. You may also contact us directly and request removal at email@example.com.
Other ways we may process your data
In addition to those purposes set out above for which we may process your Personal Data, we may also process any of your Personal Data where we are required to comply with a legal obligation or to protect your vital interests or the vital interests of another natural person, to operate its systems properly, or to protect ourselves and our users.
Information we receive from other sources
We work alongside third parties (including our service providers and Barclays Merchant Services). We may receive information from them about you. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above.
Disclosure of your information
You agree that we have the right to share your Personal Data with third parties, including:
- Our hosting provider / web site developer and Merchant Service provider.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your Personal Data to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.
- If we are acquired by a third party, in which case Personal Data held about our customers will be transferred to the third party.
- If we are legally obligated to disclose or share your Personal Data, or in order to enforce or apply our Terms and Conditions (https://www.theholidaylet.com/terms) and other agreements; or to protect the rights, property, or safety of theholidaylet.com, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
Where we store your personal data
All information you provide to us is stored on a secure server at our hosting provider inside the European Economic Area ('EEA', at Namesco, registered office address; Acton House, Perdiswell Park, Worcester, WR3 7GD.
Our website has SSL encryption provided by Geotrust.
Please note; the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We are committed to ensuring that your information is secure. To prevent unauthorised access we have put in place suitable physical, electronic and management procedures to help safeguard the information we collect from you.
Security of Payment (credit/debit cards) Details
We use Barclays Merchant services for online orders; for new advert submissions, for existing advert renewals and for featured advert purchases. Card details are encrypted before being sent directly to servers within Barclays network. We receive a confirmation of the order status from such processing, but we do not and cannot access customers payment details at any time during the transaction. We are compliant with the Payment Card Industry Data Security Standard (PCI DSS).
Transfers of your personal data outside of the EEA
Your Personal Data may be transferred outside of the EEA in order to carry out the services We provide to you.
The lawful basis for this processing will either one or more of the following:
- on the basis of your informed consent
- necessary for the performance, fulfilment and administration of an order
Where international transfer is required, as per GDPR guidelines it will be transferred only when there is an adequate level of personal data protection.
Our website and advertising service is directed at individuals who can make holiday booking enquiries or advertise holiday properties. Those individuals should be legally able:
- To enter into a booking contract with an advertiser of a holiday property
- To register / create / submit / pay for an order on our website
We will not intentionally collect or maintain information about individuals who are below the legal age to enter into any booking or who have created or paid for an advert. If you believe that we might have collected Personal Data from someone below the legal age for that area, please let us know by emailing firstname.lastname@example.org We will then take appropriate measures to investigate and to delete that information.
How long we store your personal data
We will retain your information for as long as needed to provide you with your registration or advert, or as long as is reasonably expected in order to complete a new registration or new advert. Where adverts are completed and have been purchased we are required to retain your information throughout the remaining advertising period and any subsequent renewal. If you choose not to renew an advert, we will keep your details only as long as is necessary.
We may also be required to retain certain information by law and / or for legitimate business and accounting purposes. You may instruct us to provide you with any Personal Data we hold about you. Assuming your request is appropriate we will provide this information free of charge.
How to tell us when to stop processing your data
You may instruct us at any time not to process your personal information for marketing purposes. The rights you have under the GDPR are:
The right to access;
You have the right to ask us to confirm whether or not we process your Personal Data, to have access to the Personal Data and any additional information. That additional information includes the purposes for which we process your data, the categories of Personal Data we hold and the recipients of that Personal Data. You may request a copy of your Personal Data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
The right to rectification;
You have the right to have any inaccurate information that we hold about you to be rectified. Where necessary for the purposes of the processing you also have the right to have any incomplete Personal Data about you completed.
The right to erasure;
In certain circumstances you have the right to have Personal Data that we hold about you erased. This will be done without undue delay. These circumstances include the following:
- If it is no longer necessary for us to hold your Personal Data in relation to the purposes for which they were originally collected or otherwise processed.
- If you withdraw your consent to any of the processing which requires that consent.
- If the processing is for direct marketing purposes.
- If the Personal Data have been unlawfully processed.
There are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
The right to restrict processing;
In certain circumstances you have the right for the processing of your Personal Data to be restricted. This is the case where:
- You do not think that the Personal Data we hold about you is accurate.
- Your data is being processed unlawfully, but you do not want your data to be erased.
- It is no longer necessary for us to hold your Personal Data for the purposes of our processing, but you still require that Personal Data in relation to a legal claim.
- You have objected to processing and are waiting for that objection to be verified.
Where processing has been restricted for one of these reasons, we may continue to store your Personal Data. However, we will only process it for other reasons:
- With your consent.
- In relation to a legal claim.
- For the protection of the rights of another natural or legal person.
- For reasons of important public interest.
The right to object to processing;
You can object to us processing your Personal Data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
The right to data portability;
You have the right to request that your Personal Data be moved, copied or transferred from one database, storage or IT environment to another.
The right to complain to a supervisory authority;
If you think that our processing of your Personal Data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
The right to withdraw consent;
To the extent that the legal basis we are relying on for processing your Personal Data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. Please also see the Important Notice above, beneath "Right to Erasure".
Important Notice: If you have a live advert with us and it has a remaining period of advertising and you withdraw consent or ask us to restrict the processing of your personal data, any live adverts will NOT be able to continue to be advertised as this breaks the Terms and Conditions of advertising with us i.e. - we will be unable to perform one or more of the following requisite procedures:
- forward property enquiries to you which are made via your advert contact form.
- communicate with you regarding your advert expiration or renewal notification.
- communicate important news to you about your advert, or about the website.
If you choose to withdraw consent we will place your advert in an offline status and will attempt to advise you accordingly, however at all times we will adhere to your request to withdraw consent.
The right to object to direct marketing
As our legitimate interest we may occasionally send marketing emails to you if you have made a previous enquiry about a property advert. If you wish to object to these emails we provide an opt-out option, or you can ask us to stop sending you further emails by emailing email@example.com. If you wish to:
- Request access to, deletion, correction or have your personal information transferred to another person, please contact us at firstname.lastname@example.org.
- Complain to the Information Commissioners Office (ICO), you can do so here: https://ico.org.uk/. We would appreciate that in the first instance that you contact us, at email@example.com so we can attempt to resolve any issues.
Third Party Website Links
Our site links to third party websites (namely advertisers' own websites, however we may on occasion link to other third party websites of interest). If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for those policies.
You can contact us via;
- The site contact form; https://www.theholidaylet.com/contact
- By email; firstname.lastname@example.org
- By post, to; 9 Cadbury Road, Moseley, Birmingham B13 9BH
- By telephone; +44 (0) 191 581 8169