Privacy and Cookies Policy
About this policy
The Data Controller (the organisation responsible for looking after your data) is Breakwater Holidays. When we say “we”, “our”, “us”, etc., that’s who we’re talking about.We are grateful for the trust you place in us, to arrange holidays, manage holiday properties and to use personal information responsibly. We are committed to protecting your information and we believe you have a right to know how we will use it. This policy sets out the data protection principles we follow.
This policy covers our dealings with customers and owner – people who have booked or are looking for a holiday, and people who let their holiday properties through us. Please note that our customers and owners must be over the age of 18 and we do not therefore collect personal information from children.
We will update our Privacy and Cookies Policy as data protection law or business practice changes. You can always find the latest version of this policy on our website, www.breakwater-holidays.co.uk. This version of the policy is effective from 23 May 2018.
Data Protection Officer
Our Data Protection Officer is Bridget Reps, who may be contacted via email at firstname.lastname@example.org or via post, to Breakwater Holidays, ‘Kariega’
2 Lanveans, Cleavelands, Bude, EX23 8AB, UK.
Personal information we collect
In order to provide you with the best possible holiday service, we collect the following information:
Identification: name, title, age/age range, gender.
Contact details: postal addresses (main and billing), phone numbers, email addresses.
Account login details: email address, password (which is stored in encrypted form).
Bookings: property booked, holiday start/end dates, cost of holiday, amounts paid, limited details of other people booked on the same holiday.
Marketing preferences: whether you wish to receive email marketing information from us.
Payment: method, card numbers, payment card expiry date, amounts collected, third party payment service provider references. Please note when making an online payment we do not capture or store your full card details. When payment is made by phone card details are not retained : payment is handled by our payment service provider (see below).
Browsing: historical searches, how you use our website and mobile apps, the devices and IP addresses you use to access our services (operating system, browser, …). We collect this information so that we can continuously improve our website and our service to you.
Holiday experience: any feedback you leave, responses to customer satisfaction surveys.
Specific to property owners: addresses of your properties, historical and future booking information (see above), photographs/videos of the properties you own.
Communication: emails, responses to questionnaires, competition entries, your interaction with our marketing (clicking links in our marketing emails, for example – we track this to help ensure our communications are relevant and interesting).
Electronic identifiers: cookies, IP addresses. These electronic identifiers are essential to enable you to log into your online account and to assist you if you encounter difficulties using our online services. You can disable cookies if you wish, but this will hamper our ability to provide online services securely.
Through our partnerships, we may receive some of the above information from other companies you use (e.g. other online holiday companies that feature our properties). In such cases, those companies must also inform you about their use of your data.
How we use your personal information
We use your personal information to:
- Manage your holiday booking/letting
- Ensure you can log into your online accounts with us
- Understand how to improve our services, to select the best holiday properties and provide the best information and offers, for example
- Detect and prevent fraud or abuse of our services
- Personalise your online experience – showing you the most suitable holiday properties, for example
- Enable the display of the most appropriate adverts on our websites and on other websites and services where we place advertising
- Communicate with you, including for example, responding to your emails, messages on social media, handling customer service matters and so on
- Process your payments
- With your permission, send you relevant marketing information such as details of competitions, special offers and properties we think will be of interest to you
- Manage competitions, promotions and special offers in which you participate
- Make sure our servers and websites are operating correctly
How we collect personal information
We receive personal information from:
- You, as you provide it to us (e.g. when booking a holiday, leaving a review or enquiring about letting a property)
- Your use of our website and mobile app
- Third party holiday providers you may book with, who advertise our properties
- Your interaction with our marketing activities (provided you have not unsubscribed)
- Third party review services such as TripAdvisor
Legal basis of processing
There are several grounds on which we will store and use your data. As follows:
Consent: for certain types of processing (e.g. marketing activities), we rely on your consent to use your data. You may withdraw your consent at any time (see “Your rights”, above).
Contract: much of the time, our use of your data will be because of the contract between us – that is, in relation to your holiday booking. We will usually retain relevant data for up to six years from the date the contract completes – e.g. the last day of your holiday.
Legal obligations: we are under certain binding legal obligations, such as accounting to the government for tax and making financial records available for audit. In such cases, we are typically obliged to retain data for up to seven years from the date of the transaction.
Legitimate interests: we use data to manage our operations and to make business process improvements. Rest assured, our legitimate interests will never override your right to privacy
How we share your personal information
We sometimes give some of your contact information to property owners, so they can get in touch about key collection and so on. (We also give you their contact details, for the same reason.)
If you permit us to send you marketing information, we may share your data with companies that provide specialist marketing platforms. These companies are under strict obligations to protect your privacy and comply with your marketing preferences. Our marketing partner companies are:
- Mailchimp, The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE,
- Suite 5000, Atlanta,GA 30308 USA
- TripAdvisor LLC, 400 1st Avenue, Needham, MA 02494, USA
We also use a third party booking site which is linked to our website. The information stored on this system is not shared.
- Holiday Bookings Online Ltd, 9 High Street, Wellington, Somerset TA21 8QT
Security of your data
We protect your data with various technological measures. We also regularly test and evaluate the security of our systems, updating safeguards as appropriate.
Payment service provider
When payment is made online we do not have access to the full card information.In order to ensure your transactions are as secure as possible, we hand over payment card processing to the following supplier:
- Worldpay (UK) Ltd, The Walbrook Building, 25 Walbrook, LONDON, EC4N 8AF
We allow some third party advertisers to place cookies on our websites – and from there, in your browser. Please note that you may use your browser’s controls to disable cookies at any time.
We generally use your data either on the basis of your consent, or based on a contract between us (e.g. when you book a holiday). You have the right to withdraw your consent. All our marketing communications include an unsubscribe link, to make it easy to withdraw consent.
If you withdraw your consent (e.g. by opting out of marketing communications), we will stop processing your data as requested. Do bear in mind if you have a holiday booked and you have not yet travelled, we’ll still need to hold onto your data so we can process the holiday but you are still free to unsubscribe to marketing emails.
You have the right to receive a copy of your personal data. You also have the right to request that we correct or remove your data, when there remains no legal basis for keeping it. Please note that when these rights are exercised, we will conduct identification checks in order to ensure your privacy is safeguarded. You will need to contact us by email or post, to exercise these rights
If you are concerned about the processing of your data, please contact our Data Protection Officer (see above). If you are unhappy with our use of your data, you also have the right to make a complaint to the Information Commissioner’s Office, which supervises data protection in the UK.