This policy and the terms and conditions on the website set out the legal basis for which we collect any personal data from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the General Data Protection Regulation 2018 and the Privacy and Electronic Communications Regulation (the Acts), Fin-Ex FB 1HG (UK) Limited acts as the data controller for Coppa.

CONTACT

Should you have any questions, queries or requests regarding your data in relation to Coppa please contact marketing@thecalix.com.

ACCEPTANCE OF THE PRIVACY POLICY

By using our website or any other of our direct channels (email, phone, direct communication), you agree to the terms of this Privacy Notice. Please ensure that you read this Privacy Notice carefully.

We may modify this Privacy Notice from time to time. We will notify you of material changes to this Privacy Notice by posting an amended terms notice on our website. If you do not agree with the proposed changes, you should discontinue your use of our direct channels before the new Privacy Notice takes effect. By continued use of our channels, you will be bound by the modified Privacy Notice.

1. About this document

This document sets out our privacy policy in respect of processing and use of customer, client or supplier personal data that you provide us with. We are committed to ensuring the protection of the personal and private data that you give to us but does not in any way constitute a contract. Please see Section 19 below for the rights which the law provides you with in relation to your personal data.

2.Why we need your data

There are four reasons for processing your data.

  • To provide you with a more personalised service that reflects your needs when frequenting our business or doing business with us.
  • To allow us to make a reservation for your booking or party and take a holding deposit for that booking or party
  • For the safety and security of our patrons and staff.
  • For fraud prevention

In section 8 we will explain further what legal basis we have for collecting this data.  In section 10 we will explain in detail at what points we will collect personal data from you.

3.Copyright notice

All copy on our website including this document are copyrighted 2018 to Fin-Ex FB 1HG (UK) Limited.

4.About us

Fin-Ex FB 1HG (UK) Limited is registered with Companies House and fulfils its duties under all relevant legislation.  Our registration number is 11231702 and we are registered at 1 Harrington Gardens, London. SW7 4JJ.  We are registered with the Information Commissioner’s Office under the reference ZA351900.

All our companies comply with all relevant provisions of the General Data Protection Regulation 2018 and Privacy & Electronic Communications Regulation 2003.

5.Contacting us

If you have any concerns about how your data is being used, you wish to make a subject access request, or you wish to request the removal of your details from our databases please contact us at marketing@thecalix.com.  Should you wish to make a subject access request you can do so in writing however this may be subject to a £10 fee which is in line with ICO recommendations.

For the basis of GDPR and data processing our data protection officer can be contacted at marketing@thecalix.com.

This can also be done by sending us communications in writing to

Data Protection Officer
Coppa
1 Harrington Gardens
London, SW7 4JJ

6.Our Commitment

The privacy of those that come into contact with our business is important to us.  We may collect various types of personal data at different stages throughout your dealings with Coppa.  By reading the details below we hope that you will feel confident that we have strong privacy policies in place to make sure that the data that you do gift to us treated with respect and held in as secure a manner as possible laid out in recommendations from the ICO.

7. Who our privacy policy covers

7.1 OUR CUSTOMERS

Our privacy policy sets out how we process personal data (including information) relating to individuals who are booking, enquiring or working as service providers and contractors with or through us, or who are the recipients of a booking or enquiry with us (e.g. you are a guest within the booking or enquiry made by someone else for you).

7.2 EXAMPLES OF WHO THIS POLICY COVERS

We include in this privacy policy personal data we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors.

7.3 WHEN WE ARE DATA PROCESSOR ONLY

When we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party such as an online reservation system like Opentable.com, and not on our own account, we will only be seen as the data processor and not the controller. In this case, you should look to that third party’s privacy policy.  Under the GDPR, it is the data controller that is required to inform us of any changes to the data they have supplied to us. That third party shall be responsible for how we process that personal data. We will however endeavour when possible to correct this data or remove it should we receive a request in writing.

7.4 TERMS USED IN THIS POLICY

When we refer to “you” and “your” in this privacy policy, we refer any such individual whose personal data we process from time to time. When we refer to “processing” of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

8. What laws we comply with

We process your personal data in accordance with the following data protection law(s): The United Kingdom Data Protection Act 1998 (which covers protection of personal data generally), General Data Protection Regulations 2018 (which overrides the previous Data Protection Act) and The Privacy and Electronic Communications (EC Directive) Regulations 2003 of England and Wales (which covers, among other things, the use of telephone numbers, fax numbers and e-mail addresses for unsolicited direct marketing). Our regulator is the UK Information Commissioner: http://www.ico.org.uk/. We also comply generally with the laws of England and Wales in relation to the processing of your personal data, and not any other laws.

Under GDPR the following are the legal bases for data processing:

>>

Legal Basis When this is relevant Who it effects
Consent There are three points at which you will be asked to consent to us processing your data.

  1. When using our website you will be asked to consent to us tracking your IP address and other personal data that can be linked to this. This will be in the form of a cookie and will be anonymised until you give us your full name or other such identifying personal data.
  2. By making a direct reservation with us we will process your data to allow us to complete that reservation. We will also send you some communications via email that may be of interest to you before your arrival.  At any point you may stop these marketing communications by unsubscribing.
  3. On booking a party you will be required to fill out a party booking form which will have some required data fields that we need to conduct business and to ensure the safety  and security of all our guests.  It is for this reason that we also require photographic id on check in.  At this point you will be asked to opt-in to receiving marketing communications from us in the form of newsletters, offers and news from Coppa.

Please note that children are discussed in a separate section within this document.

General Customers who book directly with us or  who use our website.
Legitimate Interest When making an enquiry with us, or making a booking through a third party (i.e. Opentable.com) we may require some personal data from you that we will use to process the booking or enquiry. By filling out your details through a third party or in an enquiry from you acknowledge that we may process your data.

 

Should wish to opt-out of this data processing and subsequent marketing, this can be done by either contacting us directly or  clicking on an unsubscribe link on any email we may send.  Once this has been done your data will be marked as not wishing marketing communications from us, this will only be changed through your re-consent.  We will still however store your personal financial data for up to 6 years as is required by UK law.  Unless you request your details to be deleted; as is your right under GDPR

We have a legitimate interest in collecting the personal data of our employees that will allow us to process salaries as well as for safety and security reasons. (please see section 9.11 for more details)

We have a legitimate interest in the storing of payment details allowing us to complete transactions with you.  Any storage of this sensitive personal data will be encrypted and stored securely in the cloud.

Customers booking through a 3rd party or those who have submitted an enquiry directly to us through email or phone.
Contract Should you enter into a contract with us either as a supplier or partner, by signing your contract your give us consent to process your personal data to allow us to fulfil our contract obligations.  We will however not send you any marketing communications unless you have expressly consented to this. Suppliers and partners.

 

9.What types of personal data we process

This section summarizes the types of personal data about you that we process:-

9.1 DATA CONCERNING YOU AS AN INDIVIDUAL

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, loyalty card member numbers, and any other information provided to us by or in relation to you which concern you as an individual..

9.2 BUSINESS RELATED INFORMATION

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.3 ENQUIRY AND BOOKING INFORMATION

Information concerning enquiries and bookings made with or through us for table reservations, party bookings or other events, including where you are making the enquiry or booking or are the recipient of the reservation to which the enquiry or booking relates. This information may include: records of enquiries and searches for table reservations and products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; payment details (including card details); and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

9.4 PERFORMANCE INFORMATION

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during a stay, and information relating to payments to be made..

9.5 SURVEY INFORMATION

Information collected or generated out of any surveys we conduct.

9.6 COMPETITION INFORMATION

Information collected or generated out of any competitions or promotions we run.

9.7 ACCOUNT, REGISTRATION AND LOYALTY INFORMATION

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

9.8 CORRESPONDENCE

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

9.9 WEBSITE USAGE INFORMATION

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website. This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally. This information may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

9.10 Social Media Information

Our Platform includes social media features that may be managed by us or by third parties. These features may collect a visitor’s IP address and which pages the visitor is visiting, and may set a cookie to enable the feature to function properly. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services.

We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

9.11 As Employees of the company

We will collect both standard and sensitive personal data of all those who are either under permanent employment contracts or sub-contractor contracts.  This will be in the form of name, address, data of birth, national insurance number, bank details and personal email address.  We will also conduct a health screen on taking up employment which will be kept in the employees’ personnel files until their contract ends.  To allow us to comply with UK immigration policy we will also store photographic ID I the form of a passport.  By entering into a contract with The Harrington Collection you acknowledge that we have a ‘contractual’ legal basis for processing this data.  It is the employees’ responsibility to keep this data up-to-date.

10. How we collect or generate your personal data

This section sets out the ways in which we may collect or generate personal data concerning you.  Some of the ways are set out in brief below with further details after.

  • From the visitor’s browser, such as the screen resolution, operating system name and version, device manufacturer and model, language, or browser type and version.
  • Through a visitor’s activities offline, for example when a visitor responds to a newsletter or interacts with us by telephone.
  • Through the visitor’s activities online, such as when a visitor responds to an email, fills out an online form or responds to a survey.
  • Through social media.
  • Through cookies and other technologies that help us track and analyse how visitors interact with our Website.

By receiving additional information from third parties

10.1 VISITING OUR WEBSITE

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

When you visit our website for the first time, we will ask you for permission to use cookies to enhance your user experience on our website.  You are not required to give us permission to be able to make bookings on the site, however it will allow us to give you a better experience.

You can find this and further information about cookies at http://www.aboutcookies.org.

10.2 DATA YOU PROVIDE

Your personal data will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

10.3 DATA OBTAINED FROM THIRD PARTIES

We may obtain personal data concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

10.4 DATA GENERATED BY US

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal data or data gained from your use of our website. We will record that telephone calls have taken place between you and us and may at time record telephone calls with you.  If recordings are made you will be informed during the conversation and may request these recordings at any time as part of a subject access request.

10.5 The Data of children

Our content is neither directed towards minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we become aware that a minor or a child under the age of 13 has provided us with personal information without parental consent, that information will be deleted. Parents who have questions about personal information that may have been submitted by a child under the age of 13 should email us at marketing@thecalix.com.

Please note that we have the right under UK legislation to ask for photographic ID for anyone requesting the purchasing of alcoholic beverages, including those under the age of 18 and can only serve alcohol in accordance with current UK legislation.

11. What do we use your personal data for?

This section sets out the uses which we make of your personal data:

  • Send administrative information to the visitor;
  • Remember the visitor’s preference, such as language, font size, when using our Website;
  • Remember the visitor’s interests;
  • Administer our Website, diagnose technical problems, and otherwise manage our business;
  • Facilitate the visitor’s use of the Website;
  • Allow the visitor to navigate or browse through our Website quickly and efficiently;
  • Personalize the visitor’s experience by presenting content that is tailored to that specific visitor based on what we know about that visitor;
  • Keep records of contact information and correspondence;
  • Send marketing information;
  • Communicate with the visitor about our activities;
  • Send invitations to events that may be of interest to the visitor;
  • Facilitate social sharing functionality, such as sharing content, through social media networks;
  • Allow the visitor to share content with a friend through the Website; by using this feature, you guarantee that you have the right to use and provide us the names and email addresses you submit.
  • Improve, test, and monitor the effectiveness of the Website;
  • Develop features for the Website that may be of interest to our visitors;
  • Optimize our marketing efforts, for example by compiling statistics regarding the use of the Website, identifying usage trends, or measuring the effectiveness of our promotional campaigns;
  • Perform data analysis, audits, security and fraud monitoring and prevention;
  • Enhance, improve, or modify our Website; identify usage trends;
  • Help diagnose technical problems, and detect spam behaviour, denial of service attacks or other cyber-threats.
11.1 OPERATE OUR WEBSITE

To operate and provide the search, booking, accounts, review and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

11.2 PROVIDE INFORMATION AND RESPOND TO ENQUIRIES

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches, and to keep you updated generally.

11.3 BOOKINGS AND OTHER CONTRACTS

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

11.4 PAYMENTS

To collect and make payments due and administer our accounts.

11.5 COMMUNICATION WITH CUSTOMERS

To communicate with you concerning any enquiries, bookings, problems and complaints, and to respond to any submissions, enquiries or requests from you.

11.6 RECORD KEEPING

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, and complaints.

11.7 MANAGE AND IMPROVE OUR BUSINESS

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

11.8 DIRECT MARKETING

To carry out direct marketing to you. See next section below for further information.

11.9 ADVERTISING

To report aggregate information concerning usage of our websites to our advertisers. We will normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

11.10 ANYTHING YOU HAVE SPECIFICALLY CONSENTED TO

For any purpose which we have obtained your consent to.

11.11 EMPLOYEES, SERVICES AND PARTNERS

We share information with our employees, suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with advertising, hosting, data analytics, information technology and infrastructure, email delivery, auditing, and other related activities.

11.12 SOCIAL MEDIA

Our website may include links to third party websites and social media services where a visitor is able to post comments, reviews or other information. Please note that any information that is posted or disclosed through these social media services may be available to us, or to other visitors of that service or the public. We recommend caution when using these features.

12.Our use of cookies and other tracking software

12.1 COOKIES AND TRACKING TECHNOLOGY

We use cookies, beacons, pixels, tags, statistical IDs, flash cookies, and similar tracking technologies to collect information about the activities of our visitors and registered user over time and across different Sites, such as the pages a visitor views, the links on which a visitor clicks, how frequently a visitor accesses the Platform, and other visitor attributes and behaviours.  We also collect log file information from a visitor’s browser such as web request, IP address, browser type, referring / exit pages and URLs, and landing pages.  We may use statistical modelling tools to attempt to recognise visitors across multiple devices.

We may retain the services of third party service providers who may link personal information about a visitor – such as name or email address – to other information they may have – for example, past purchases. This information may allow us to identify assumed interests or preferences of that visitor, so that we can provide a visitor with more useful and relevant offers or services.

We use cookies and tracking technologies to, among other things:

  • Display information more effectively;
  • Gather statistical information about the use of the Platform, to understand how our Platform is used, and improve design and functionality;
  • Store, on a visitor’s device, information about that visitor’s preferences and settings;
  • Recognize a visitor when the visitor moves from page to page, or returns to use the Platform;
  • Collect information such as browser type, time spent on the Platform, pages visited, and traffic data;
  • Track responses to our marketing and advertising campaigns; and
  • For security purposes.

We also use these technologies to understand the activities and interests of our visitors, including to:

  • Measure traffic and usage of our Platform;
  • Monitor the effectiveness of our Platform;
  • Better understand the interests of visitors;
  • Recognize new or past visitors to our Sites;
  • Present more personalized content and advertisements;
  • Optimize a visitor’s shopping experience;
  • Identify visitors across devices, and third party websites; and
  • Identify improvements or enhancements to our Platform that might be of interest to our visitors
12.2 HOW TO BLOCK COOKIES

You can control some of our use of cookies. How you do so depends on the type of cookie. You may be able to configure certain browsers to delete or disable browser cookies. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the “options” or “preferences” menu of a browser. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies and http://www.allaboutcookies.org/browsers/index.html for information on commonly used browsers.

To control flash cookies, you can visit:  http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Platform. Choices you make about cookies are also browser and device specific. Further, while disabling a cookie may prevent the collection of information in the future, it does not prevent the use of information collected before the cookie was disabled. If you block or delete cookies, not all of the tracking described in this notice will stop.

Analytics

Information collected by Google Analytics is transmitted to, and stored by, Google in accordance with its privacy practices.  To see an overview of privacy at Google and how this applies to Google Analytics, please click here: https://support.google.com/analytics/answer/6004245.

To opt out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout.

In addition, some third-party businesses may provide a mechanism to opt-out of their technology.  For more information about the opt-out process, you may visit the Network Advertising Initiative, you may want to visit:

http://optout.networkadvertising.org/#/ and  http://www.networkadvertising.org/managing/opt_out.asp.

Mobile device visitors may also download the AppChoices app at:

www.aboutads.info/appchoices to opt out from interested based advertising served in mobile apps.

13.Use of your personal data for direct marketing

We do not use or disclose your personal data for direct marketing purposes unless we have obtained your consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

13.1 DIRECT MARKETING BY US

Where you have consented to this, we may use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to services we provide or which can be booked with third parties through us. You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert “unsubscribe” as the subject heading.

13.2 DIRECT MARKETING BY THIRD PARTIES

Where you have consented to this, we may disclose your personal data which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal data for this purpose at any time, by contacting us as detailed above. If you withdraw your consent.  Should you inform us that you wish your name to be withdrawn or that your details need updating, we will inform these third parties on your behalf.

14. Disclosure of your personal data

We transfer your personal data to third parties in the following circumstances:-

14.1 CREDIT CHECKS ETC.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

14.2 BOOKINGS AND PERFORMANCE OF CONTRACTS

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

14.3 SUPPLIERS OF ONLINE RESERVATIONS AND OTHER SERVICES

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel packages or other products or services we have agreed to provide to you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier). Details of any third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

14.4 INSURANCE

If any application is made through us for any insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

14.5 BUSINESS FUNCTION OUTSOURCING

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes.

14.6 PUBLIC FORUMS ETC.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility) then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

14.7 LEGAL REQUIREMENTS

We may supply personal data to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal data where otherwise required by or permitted by law.

14.8 DIRECT MARKETING BY THIRD PARTIES

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

14.9 CUSTOMER REPRESENTATIVES

If our customer is a business or organisation, and we are holding your personal data in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

14.10 BUSINESS ACQUIRERS

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.

15.How third parties will handle your personal data

Where we provide your personal data to a third party one of the following two circumstances will apply:-

15.1 PROCESSING ON OUR BEHALF

In some cases, your personal data may be held and otherwise processed by them on our behalf, in which case we will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy.

15.2 PROCESSING ON THEIR OWN ACCOUNT

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure

16. Location of your personal data

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere in the world. Where we disclose your personal data to third parties, that disclosure may also involve a transfer of your personal data anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world. In each case, we will comply with any legal requirements concerning the transfer of your personal data by us to any third party outside the country where we are established, and where your personal data is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

17.Keeping your data secure

17.1 OUR SECURITY MEASURES
17.1.1 OUR GENERAL COMMITMENT

We are committed to doing what we reasonably can to keep your personal data secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

17.1.2 TRANSMISSIONS BETWEEN YOUR WEB BROWSER AND OUR SERVERS

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

17.1.3 STORAGE OF YOUR PERSONAL DATA

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

17.2 YOUR SECURITY MEASURES

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information. We also encourage you to be careful about who you give personal data to. We never contact you to ask you for sensitive personal data, such as payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

17.3 INTERNATIONAL TRANSFER OF DATA

In accordance with the GDPR we will not transfer any personal data to bodies whose legal entity resides outside a European jurisdiction or countries who have data protection legislation that offers similar data protection to the GDPR.  Should any international transfer of data occur then we will conduct a Privacy Impact Assessment to look at the risks of transferring this data.

18.How long do we keep your personal data for?

We keep your personal data for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal data may be relevant to any possible liability we may have to you.

18.1 RIGHT TO BE FORGOTTEN

Should you wish your data to be removed from our system, you may request in writing for your data to be destroyed, which will be done within 21 days of receiving your written request. Your name and email will still be retained within our unsubscribe lists so that we can be assured of not contacting you again.   We retain the right to keep personal data that complies with UK law, e.g. we will keep all invoices for 6 years enabling us to meet UK tax regulations.  We shall also store sensitive data in relation to bookings for up to 6 years to allow us to comply with any UK law enforcement.  However should a request to be forgotten be made, then your personal data will no longer be general processed for or business needs but rather stored securely in a data archive.

19.Your Rights

Our privacy policy is not intended to create a contract or form part of any contract. You have certain non-contractual rights under the laws noted above, which we summarize below. If you contact us about these rights, we may ask for proof of your identity before we act, and may refuse to act if you do not provide this or your identity is not established by you.

19.1 ACCESS TO YOUR PERSONAL DATA

You may make a subject access request at any time in writing to the data controller at our registered address above.  This may be subject to a £10 fee which is in line with ICO recommendations dependent on the complexity of the request. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

19.2 USE CAUSING SUBSTANTIAL DISTRESS OR DAMAGE

You have the right to ask us to stop using your personal data for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions laid down by the GDPR

19.3 USE FOR DIRECT MARKETING

You have the right to ask us to stop using your personal data to carry out direct marketing to you.

19.4 CORRECTION OF INACCURACIES

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal data we hold about you.  However we will do our best where possible to make sure that your records are kept up to date where you yourself cannot make the corrections.

19.5 COMPENSATION

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

19.6 COMPLAINTS TO APPLICABLE AUTHORITY

The laws we comply with are regulated by the Information Commissioner (www.ico.gov.uk) in the United Kingdom. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

20.Changes to this privacy policy

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes. You should check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

21.Applicable Law And Disputes

This policy is subject to the law of England and Wales, and you must bring any claims against us (non) exclusively in the courts of England and Wales.

22.Acceptance of this policy

This policy has been agreed to and signed off by senior management.