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LANDSCOVE HOLIDAYS LIMITED
PRIVACY POLICY

Landscove Holidays Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites www.landscoveholidays.co.uk and www.riverabay.co.uk (regardless of where you visit them from), when you enquire about our holiday homes (whether as a prospective guest or prospective buyer), when you book one of our holiday homes as a holiday rental, when you become an owner of a holiday home on one of our sites or when you otherwise contact us. It will also tell you about your privacy rights and how the law protects you.

 

1   IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

1.1  This privacy policy aims to give you information on how Landscove collects and processes your personal data through your use of our websites (including how Landscove collects and processes data you provide to us through our websites, for example when you enquire about our holiday homes whether as a prospective guest or prospective buyer, or request other information from us), when you book a stay with us, when you become an owner of a holiday home on one of our sites, when you apply to work with us (whether by responding to an advertised vacancy or sending us a speculative application or enquiry) or when you otherwise contact us.  

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

Controller

1.3  Landscove (collectively referred to as “Landscove”, “we”, “us” or “our” in this privacy policy) is the controller and responsible for your personal data.

1.4  If you have any questions about this privacy policy, including any requests to exercise legal rights, please contact us using the contact details in section 10.

Changes to the privacy policy

1.5  Any changes we make to our privacy policy in the future will be posted on this webpage and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Third-party links

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

2  THE DATA WE COLLECT ABOUT YOU

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

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

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, and, as part of our recruitment processes, details of your qualifications, skills, experience, employment history, salary information, information about entitlement to work in the UK and equal opportunities monitoring information. In limited circumstances, we may need to collect information relating to health in connection with an accident or incident which occurs on our sites.

  • Contact Data includes address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of stays and other services you have purchased from us.

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

  • Profile Data includes your username and password, purchases or bookings made by you, your interests, preferences, feedback and survey responses.

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

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

2.3   Certain personal data that we collect are treated as Special Categories of Personal Data to which additional protections apply under data protection law. For example, we may need to collect health data in connection with accident or incident forms, and, as part of our recruitment process, we will collect, use and process Identity Data which may include disability information and other equal opportunities monitoring information. Where we process such special category personal data, we will ensure we are permitted to do so under data protection laws. Outside of these contexts, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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

If you fail to provide personal data

2.5   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 the contract we have or are trying to enter into with you (for example, to process your booking). In this case, we may have to cancel provision of our services but we will notify you if this is the case at the time.

3  How is your personal data collected?

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

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • enquire about and/or book one of our holiday homes;

  • create an account on our website;

  • subscribe to our mailing list;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or otherwise contact us.

·   Information we receive from other sources (as part of our recruitment processes). We may receive information about you from third parties who we have asked to conduct pre-employment checks about you and/or former employers when they provide references.

·    Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy in sections 4.11 to 4.16 for further details.

·   Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

o    Technical Data is collected from analytics providers such as Google.

o    Identity, Contact and Transaction Data is collected from providers of technical, payment and delivery services such as ParcVu and Opayo. We engage Opayo to provide secure payment services; whilst we may receive Transactional Data from Opayo we do not receive your Financial Data. For more information see Privacy policy (elavon.co.uk).

4   How we use your personal data

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

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

  • Where it is necessary for our legitimate interests (or those of a third party), for example to give you the best and most secure guest experience, and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation. We will identify the relevant legal obligation when we rely on this legal basis.

  • Where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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

Purposes for which we will use your personal data

4.2    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.3   Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Use

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer (whether as guest or as a new owner) and/or to provide our services (including our holiday homes and site management services) to you. We collect the names of all guests and owners staying at our sites for this purpose.

(a) Identity

(b) Contact

 

(a) Performance of a contract with you

 

To process and deliver your booking and/or our services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

(e) Financial

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Dealing with your requests, complaints and queries

(c) Responding to an enquiry you have submitted to us

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you

Health and safety including health and safety assessments and record keeping including compliance with related legal obligations.

(a) Identity Data

 

(b) Contact Data

 

(c) Profile Data

 

(a) Necessary for compliance with a legal obligation.

 

(b) Our legitimate interest in carrying out the processing for the purpose of ensuring safety at our premises

 

(c) The processing is necessary to protect the vital interests of any individual

 

(d) Where we obtain your explicit consent (this legal basis is only used in relation to processing that is voluntary – it is not used for processing that is necessary or obligatory in any way under the foregoing legal bases)

To conduct a recruitment process

(a) Identity Data

 

(b) Contact Data

 

(c) Marketing and Communications Data

(a) Necessary for our legitimate interests (of running a recruitment process and keeping records of such processes)

 

(b) Necessary to comply with a legal obligation (for example, in some cases it is necessary to check a successful applicant’s eligibility to work in the UK)

 

(c) To take steps prior to entering a contract of employment with you

 

(d) In relation to any special category personal data, we will satisfy the following additional conditions: processing necessary for the purposes of carrying out our obligations and exercising specific rights under employment, social security and/or social protection law and, otherwise, only with your explicit consent

 

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and

recommendations to you

about holidays that

may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Consent, having obtained your prior consent to receiving direct marketing communications.

 

 

Marketing

4.4   We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

4.5    We may use your Identity, Contact, Technical, Profile, Usage and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide services and offers may be relevant for you (we call this marketing).

4.6    You will receive marketing communications from us if: a) you have requested information from us; or b) you own a holiday home on one of our sites or you have booked a holiday home with us and you have not opted out of receiving that marketing; or c) you have provided your consent.

Third-party marketing

4.7    We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

4.8    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact details in section 10.

4.9    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in the course of performing our services to you where you have enquired about or placed a booking with us.

Cookies

4.10  We use cookies to better understand our customers and improve your online experience.

4.11   A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

4.12  We use the following cookies:

·   Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.

·  Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

·   Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

4.13  You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title

 

_ga

This cookie is used to distinguish users to our website.

_ga_<container-id>

This cookie is used to persist session state.

     

4.14   You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.15   If you have any questions or concerns about our use of cookies, please contact us using the details outlined in section 10.

Change of purpose

4.16  We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

4.17  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.18  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 Disclosures of your personal data

5.1  For the purposes set out in section 4, we may have to share personal data with External Third Parties who provide support integral to the provision of our services and enable us to operate, such as:

  • Service providers acting as processors based in the UK, Europe and/or the United States of America who provide IT, cloud and system administration services, accounting services, human resource services, payment services and customer relationship management and marketing services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and employment and recruitment agencies based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance, accounting and recruitment services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.

  • Other third party companies where we have an agreement in place and only where an individual has agreed that we may share their personal data with them.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

5.2    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6   International transfers

6.1   Some of our suppliers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

6.2  Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

6.3  Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.

 Data security

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

8   Data retention

How long will you use my personal data for?

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

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

8.3   You can request further details of retention periods for different aspects of your personal data by contacting us directly (please see section 10). 

9    Your legal rights

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

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

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

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

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

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

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

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

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

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

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

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

9.2  If you wish to exercise any of the rights set out above, please contact us.

9.3   You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

No fee usually required

9.4   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

9.5  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

9.6   We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10   Contact details

10.1   If you have any questions about this privacy policy or our privacy practices, you may contact our team in the following ways:

Full name of legal entity: Landscove Holidays Limited

Email address: info@landscoveholidaysltd.co.uk

Telephone: 01392 341953

Postal address: Newport Park, Topsham Road, Exeter, EX2 7DT

Last Reviewed: April 2024