Welcome to Your Holiday Homes Limited privacy notice.
Your Holiday Homes respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects to you.
1. Important Information and Who We Are
2. The Data We Collect About You
3. How Is Your Personal Data Collected
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Your Holiday Homes collects and processes your personal data through your use of this website or our services, including any data you may provide through this website or during events, seminars and exhibitions, when you sign up to our newsletter, purchase our service or take part in a competition.
Your Holiday Homes is made up of different trading names such as Domus Alliance (www.domusalliance.com) , Spanish Pavilion (www.spanish-pavilion.com), Portugal Holiday Homes (www.portugalholidayhomes.com), www.yourholidayhomes.se, Property pavilion (www.propertypavilion.com) . This privacy notice is issued on behalf of each trading name of Your Holiday Homes so when we mention " Your Holiday Homes", "we", "us" or "our" in this privacy notice, we are referring to the relevant trading name of Your Holiday Homes responsible for processing your data. Your Holiday Homes Limited is the controller of the data for all trading names.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
• Full name of legal entity: Your Holiday Homes Limited
• Name or title of DPO: Stefan Barbulescu
• Email address: email@example.com
• Registered address: 15-16 Vicarage Gate, London, W8 4AA
• Telephone number: 0044 208 144 5841
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 09 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your Holiday Homes websites 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 notice of every website you visit.
2. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
a. Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Request an introduction to real estate professionals and their products or services by completing a form during events, seminars and exhibitions
• apply for our products or services;
• create an account on our websites;
• subscribe to our service or publications;
• request marketing to be sent to you;
• book tickets for an event or an exhibition hosted by us or our strategic partners
• enter a competition, promotion or survey; or
• give us some feedback.
b. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
c. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:
• analytics providers such as Google based outside the EU;
• social media services
• advertising networks; and
• search information providers
3. THE DATA WE COLLECT ABOUT YOU
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
a. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title
b. Contact Data includes billing address, delivery address, email address and telephone numbers.
c. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
d. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
e. Technical Data includes internet protocol (IP) address, your login data, 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 interact with or access this website.
f. Profile Data includes your client identification number, purchases or orders made by you, your interests, preferences, feedback and survey responses.
g. Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
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 provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
4. HOW WE USE YOUR PERSONAL DATA
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) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email or text message. Where you have placed a request with us by completing a form at events, seminars and exhibitions or purchased our services we consider that you have an interest in those products or services and similar products or services offered by or through us, and we are permitted under data protection legislation to send those communications to you. We comply with data protection legislation in our electronic marketing and you have the right to withdraw consent to marketing at any time by emailing the data protection manager at firstname.lastname@example.org
Purposes for which we will use your personal data
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.
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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a customer where you purchase products or services from us (for example online marketing services, trainings, exhibition representation service)
Performance of a contract with you
To process and deliver your order including:
(a) Performance of a contract with you
To manage our relationship with you which will include:
To enable you to partake in a prize draw, competition or complete a survey
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and 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 goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To provide you with information relating to products, services or information offered by our commercial partners and to pass your data on to our partners where your enquiry matches with their products and services
Necessary for our legitimate interests (to run and grow our business, put you and our commercial partners in touch with each other, and to inform our marketing strategy)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or placed a request with us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
When you request information on products, services or properties provide by our commercial partners via Your Holiday Homes, we will pass your personal data on to them and they may contact you regarding those products, services or properties. We will get your express opt-in consent before we share personal data provided for that purpose with any other company or organisation (other than ourselves) for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
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.
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.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties such as Your Holiday Homes commercial partners.
• 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 notice.
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
If you enquire about a product or service located outside the European Economic Area (“EEA”) – for example, in New York, your personal data will be provided to the commercial partner. We may also from time to time offer information, products or services from partners outside the EEA in relation to products or services in their country or location. In each case, this will involve transferring your data outside the European Economic Area (EEA).
In many cases where you submit an enquiry about products, services or properties offered by a commercial partner (such as a real estate professional) outside of the EEA, we may be unable to ensure a similar degree of protection for your personal data as exists within the EEA. In these situations, we transmit your personal data directly to the commercial partner at your request and on your behalf . Separately, we may also use the data provided by you for our own business purposes, as set out in this Privacy Notice.
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. To find out more about these rights, please refer to paragraph 10 below:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 may refuse to comply with your request in these circumstances.
What we may need from you
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
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in common ownership or control with Your Holiday Homes, acting as joint controllers or processors..
External Third Parties
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities, who may act as processors or joint controllers, based in the United Kingdom (or abroad, in relation to properties, products or services located abroad) who require reporting of processing activities in certain circumstances.
• Commercial partners offering properties, or products, services or information related to properties, including real estate agents, property developers, private sellers, lawyers and notaries, mortgage and financial services companies, event organisers, media and marketing companies.
YOUR LEGAL RIGHTS
You 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 the 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the 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.