1.1 We are committed to safeguarding the privacy of everyone whose data we hold, this will be those have stayed, are staying or planning to stay with us or who have made an enquiry to us.
1.2 This policy applies to the personal data of those who enquire or book directly with us via email or telephone or in person and those who book through our online booking facility. This includes all who in the process of making enquiries contact us via our website contact form and via email.
1.4 The online booking system linked to our website incorporates privacy controls. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls when making a booking via our booking system, and once a booking has been made, by editing your booking form through your booking account. The online booking system, operated by Holiday Bookings Online Ltd is GDPR compliant and it is based in England.
1.5 In this policy, "we", "us" and "our" refer to Torridge House Cottages. For more information about us, see Section 12.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 If we do ever process any data such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, it would be for our legitimate interests, namely monitoring and improving our website. Use of an analytics tracking system would only ever be for our legitimate interests in improving and monitoring our website.
2.3 We may process the account data you give us. This data may include your name, email address and postal address. The source of the account data is you. The account data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business by the performance of a contract between you and us, taking steps, at your request, to enter into such a contract.
2.4 We may process your profile data, the profile data may include your name, address, telephone number, email address, gender and age. The profile data may be processed for the purposes of providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of business and the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.5 We may process your personal data, may include your mobile telephone number or email, so that we can make contact with you if for example you have forgotten to put your picnic lunch in the car and we see it in the gardens. The source of the service data is you. The service data may be communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.
2.6 We may process information contained in any enquiry you submit to us regarding our services. The enquiry data may be processed for the purposes of offering our services to you, ie replying by to your email. The legal basis for this processing is replying to your request.
2.8 We may process information relating to purchases of services, that you enter into with us. This transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [our interest in the proper administration of business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. This notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract]
2.10 We may process information contained in or relating to any communication that you send to us. This correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Financial transactions relating to our services may be handled by our payment services providers, Worldpay We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices www.worldpay.com.
3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 The headquarters of Wix.com who host our website are in Israel. The European Commission has made an "adequacy decision" with respect to Israel. Our own domain hosts and our Accountant are based in England.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) While your booking is active, ie from the date of reservation or booking, we will keep your card payment details until the final payment has been successfully processed. All card information is kept only on paper.
Other details such as your name, address and other contact details, and your agreement to our conditions of booking, will be stored for 7 years.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through the private messaging system on our website’s booking system.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; We will need appropriate evidence of your identity for this purpose, usually a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, and/or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. You can opt out at any time. You can ask us to remove any personal data we hold of yours. Please do note that if this is done it may limit the use of our services.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We do not automatically log personal data nor do we link information automatically logged by other means with personal data about specific individuals. We do automatically log user’s IP address and session information such as the duration of the visit and the type of browser used. This is recognised by the web server and is only used for system administration and to provide statistics which the business uses to evaluate use of the site.
(a) For relaying your contact form message to us.
(b) For your ease of using our website.
10. We do not publish any interest-based advertisements on our website.
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by Torridge House Cottages, which is a partnership between Barry and Barbara Terry of Torridge House, Little Torrington, Devon EX388PS.
12.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on 01805 622542;
(d) by email, to email@example.com
13. Data protection